REC~VED

CLERK’S OFFICE

FEB

6

2OU~l

BEFORE THE ILLINOIS POLLUTION CONTROL BOARD

STATE

OF

ILL(NO~S

Pollution

Control Board

Illinois Enviromnental

)

Protection Agency

)

IN THE MATTER OF:

Petition ofNoveon, Inc.

for an Adjusted Standard from

35

Iii.

Adm. Code 304.122

Dorothy M.

Gunn, Clerk

Illinois Pollution Control Board

James R. Thompson Center

100 West Randolph Street

Suite

11-500

Chicago, IL

60601

Deborah Williams

Assistant Counsel

Division of Legal Counsel

Illinois Environmental Protection

Agency

1021 N. Grand Avenue East

Springfield, IL

62794-9276

BradleyP. Halloran

Hearing Officer

Illinois Pollution Control Board

James R. Thompson Center

100 West Randolph Street

Suite 11-500

Chicago, IL

60601

PLEASE

TAKE

NOTICE

that

on

Friday,

February

6,

2004,

we filed the

Written

Expert Testimony ofHouston Flippin, a copy ofwhich is herewith served upon you.

Richard J. Kissel

Mark Latham

Sheila H. Deely

GARDNER CARTON & DOUGLAS LLP

191

N. Wacker Drive

—

Suite 3700

Chicago, IL

60606

312-569-1000

Respectfully submitted, NOVEON, INC.

‘-II

By:

~A72

~

One ofIts Attorneys

Noveon, Inc.

V.

)

)

)

)

PCB 91-17

(Permit Appeal)

)

)

)

)

ASO2-5

)

)

)

THIS FILING IS SUBMITTED

ON RECYCLED PAPER

---

RECE

WED

CLERK’S OFFICE

FEB

-

62004

STATE OF ILLINOIS

Pollution Control

Board

Petition ofNoveon, Inc. AS 02-5 For An Adjusted Standard

NPDES Adjusted From 35

ILL

ADM. Code Standard 304.122

Written Testimony of

T. Houston

Flippin

as wastewatertreatment

expert

representing Noveon, Inc. in

this

proceeding.

Introduction

and

Experience ofT. Houston

Flippin

asWastewater Treatment

Expert

Representing NoveonInc.

My

name

is Thomas Houston

Flippin.

I was retained by Noveon,

Inc in

December 1989

to provide

wastewater

treatment

services

and

have continued to

provide such services

for the

last

14

years.

During this

entire

time

period, I have served as lead process engineer on

all Noveon-Henry

Plant

matters in which

my firm

Brown

and Caidwell

has been involved. My firm was previously

known

as

Eckenfelder

Inc and

was acquired by Brown

and

Caidwell in

1998.

I received

two

degrees from Vanderbilt University. I received my Bachelor ofEngineering Degree in

Civil and

Environmental

Engineering in 1982 and my Master ofScience Degree in Environmental

and

Water Resources Engineering in

1984.

I

immediately

went to work forAWARE Incorporated in 1984

and

have remained

with

the same

•company for the last20 years in progressivelymore responsible positions

(from

project engineer to

project

manager

to

principal

engineer) in

the

area ofwastewater engineering (see Exhibit A for

resume documenting

this

experience). My firm has

changed

names twice. In 1989, we renamed

ourselves Eckenfelder

Incorporated in 1989 to honor Wes Eckenfelder

our Chairman

Emeritus

who is

still with

us today. Much ofwhat Ihave learned has been under Dr.

Eckenfelderas a

graduate student

and

as a co-worker. In 1998, Eckenfelder Inc was acquired by Brown

and CaidwelL

Duringmy career, I have personally conducted treatment

(treatability) testing of

industrial

wastewaters

and

contaminatedgroundwaters

and

developed treatment process design criteria from

test data. I have provided troubleshooting oroptimization services for wastewatertreatment

facilities

(WWTFs)

and

conducted waste

minimization studies.

I have also overseen the work

I

---

described

above, designed wastewater and contamina~ed

groundwater treatment processes, assisted

in effluent permit negotiations, supported expert testimony preparation and trained treatment plant

operators. I currently serve as lead process engineeron more technically challenging projects and to

train other engineers within the firm.

I am a licensed professional engineerin the states of Illinois, Michigan, Kentucky, and Tennessee. I

also am certified as aDiplomat in the American Academy of Environmental Engineers in the

specialty area of water supply and wastewater. This certification is held by less than 1300 people in

the United States and requires stringent peerreview and testing to acquire.

I have published 16

technical papers of which 7 are directly related to the Noveon-Henry Plant’s

issues andhave provided material for I textbook (Activated Sludge Treatment of Industrial

Wastewaters,John L. Musterman andW. Wesley Eckenfelder,Technomic Publishing Company,

1995). I also provided the technical reviewof a chapter from another textbook (“Granular Carbon

Adsorption ofToxics” from Toxicity Reduction in Industrial Efflu~nta~

PerryW. Lankford andW.

Wesley Eckenfelder, Van Nostrand Reinhold,

1992).

I have served as in instructor in numerous workshops including the following:

•

“Clarifier Operation and Maintenance” sponsored by Mississippi WaterPollution Control

Operators’ Associationin 1997;

•

“Aerobic Biological Treatment” sponsored by Tennessee State University in 1997,

1998, and

1999;

•

“Activated Sludge Treatment” sponsored by Brown and Caidwell and attended

by more than

10 industries during each offering in November 1999,March 2000, May 2001, November

2002, and November 2003; and

•

‘Wastewater Strategies for Industrial Compliance: Gulf Coast Issues and Solutions”

sponsored by Tulane University and Louisiana Chemical Association in December 2003.

Specific Design Experience Related to this Petition

I have developed the process design for following biological nitrification facilities. Eachof these are

fullyoperational today and meeting permit compliance.

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Noveon-HenxyPlant Experience:

1989 to 2004:Have provided

the

followingassistance in chronological order listed below. I have

also spent acumulative of atleast 2 months onsite atthis facility throughout the years with no more

thantwo years

elapsing between visits. My last visit to the plant was in the Fall of 2003.

•

Optimization of WWTF operations.

•

Setup, conduct and oversight of treatability testing that was used to develop process design

of C-18 wastewater pretreatmentsystem andaeration basin upgrade. Testing was also used

to set allowable loading rates of various wastestreams,.

•

TrainWW~F

operators in process optimization and analytical testing.

•

Setup,conduct and oversight of treatabilitytesting that was used to develop conceptuallevel

design criteria for alternative processes for effluent ammonia-nitrogen reduction. Developed

conceptual level designs for these alternative processes. Worked with construction cost

estimators andvenders to develop conceptual level costestimates of these alternative

processes.

•

Provided as requested guidance to Noveon regarding WWTF operations and full-scale

testing ofprocesses and procedures intended to provide reduce effluent ammonia-nitrogen.

•

Authored or reviewed

all reports submitted to Noveon by Brown and Caidwell (formerly

AWARE Incorporated and Eckenfelder mc)

during entire period of 1987 through

2004.

•

Represented Noveon in discussions with IEPA regarding the Petition for an Adjusted

Standard.

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Noveon-Henry Plant Wastewater Treatment Facilities

Manyof the terms thatI haveused above and throughout this report are definedbelow as the

Noveon-Henry Plant WastewaterTreatment Facility ç~WTP)

is described. An understanding ofthe

WWTF is critical to understanding the evaluations conducted and the conclusions reached.

The wastewater treatment facility at the Henry Plant site is owned and operated by Noveon, Inc.

This facility treats wastewaters discharged from two manufacturing areas (resins and specialty

chemicals) that were once owned by BF Goodrich. BE Goodrich sold the resin business to the

Geon Companywho later sold

it

to the PolyOne Corporation. BE Goodrich sold the specialty

chemicals business and the

site’s wastewater treatment facility to Noveon, Inc. The wastewaters

discharged by Noveon comprise about 35 percent of the total dryweather flowrate to the WW’IF

with the remaining 60 percent being discharged from the PolyOne production areas.

Wastewaters from the Noveon-Henry Plant production areas discharge to one of two places as

illustrated in Figure

1. All wastewaters exduding those from C-I 8 manufacturing discharge

directly

to an equalization tank (the PC Tank), as shown in Figure

1. The wastewaters from C-18

FIGURE 1

BLOCK

FLOWDIAGRAM

OP

WASTESTREAM

SOURCES AND

wwrr

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manufacturing discharge to apretreatmentsystem and are thenpumped to an equalization tank

(C-18 Tank). Prior work that I either conducted or oversaw definedthat the C-18 wastewaters were

causing the WWTF to be unable to comply with effluent BOD limits. These wastewaters contained

compounds that caused the bacteria responsible for organics removal, also known as BOD removal,

to slow down or become inhibited. This work also defined the pretreatmentof the C-18 wastewater

that would be required for the WWTF to treat these wastewaters while complying with effluent

BOD limits. Prior to installingpretreatment, the bulk ofthe C-18 wastewaterswere collected and

transported for off-site treatment and disposal. After this pretreatment was installed, the

pretreatment allowed the Noveon-HenryPlant to treat all C-18 wastewaters onsite while maintaining

compliancewith effluent BOD

limits. This pretreatment was not required of the other Noveon

wastewaters. This pretreatment also had no effect on effluent ammonia-nitrogen concentrations nor

would

it

have any such effect if applied to anyother Noveonwastewater.

Wastewaters from the PolyOne Plant production areas

discharge to one of two places as illustrated

in Figure 1. All wastewaters excluding those from 213 manufacturing discharge

directly to an

equalization tank (the PVC Tank). The wastewaters from 213 manufacturing discharge to a

pretreatment systemand are thenpumped to same equalization tank (PVC Tank). Prior work by

others had indicated that the 213 wastewaters were causing the WWTF to be unable to comply with

effluent Biochemical Oxygen Demand (BOD) and Total Suspended Solids (~SS)

limits. These

wastewaters contained compounds that kept solids from settling in the primary and secondary

clarifiers as well as fine solids that passed through the WWIF. Pretreatment was installed to mitigate

these affects. It has been successful in allowing the Noveon-Henry Plant to treat all 213 wastewaters

onsite while maintaining compliancewith effluent BOD and TSSlimits. This pretreatment was not

required of the other Polyone wastewaters. This pretreatment also had no

effect on effluent

ammonia-nitrogen concentrations norwould

it

have any such effect if applied to anyother Polyone

wastewater.

Stormwater from the both the Noveon and PolyOne sites and discharges from cooling towers,

boilers, and riverwater treatment are discharged to the Storm/UtilityPond (the “Pond”)

as

illustrated in Figure

1. A portion of the Pond contents are pumped through a filter to removeTSS

prior to discharge the Illinois River. The remaining portion is pumped to the PVC Tank for

subsequent treatment. The amount of Pond Water returned to the PVC Tank is a function of the

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capacity of the filter treating the Pond Water, the PVC Tank operating level, and the need for other

wastewaterto compliment the required PC Tank discharge flowrate. The PVC Tank has a minimum

allowable operating level, below which the tank mixer shuts off. Work thatI have conducted and

overseen hasindicated that the PC Tank discharge must be limited to approximately 23 percent of

the combined influent flow to the aeration basins to maintain compliancewith effluent BOD limits.

The PC Tank discharge contains compounds that can inhibit or slow down the bacteria responsible

forBOD removal if their concentrations

are allowed to exceed certaincritical concentrations. So the

amount of Pondwater diverted to the PVC Tank forsubsequent treatment increases duringawet

weatherperiod when the capacity of the filter on the pond discharge is approached, when the PVC

Tank level nears its minimumoperating level, andwhen the flow contribution of the PC Tank

discharge approaches 23 percent. The contents of the PVC Tank, PC Tank, and C-18 Tank are

pumped to a pH adjustment tankalong with groundwater from arecovery well (Well No.

3). The

pH of the combined wastewater is adjusted. Coagulant and polymer are added to the combined

wastewater to assist in removing solids from the combined wastewaterin the sedimentation basin

(also known as primaryclarifier). The solids settle for approximatelyone hour in the primary

clarifier. The settled solids then combinewith solids discharged from the bottom of the second

sedimentationbasin (also known as the secondary clarifier) and are dewatered usinga filter press.

The dewatered solids are disposed in a permitted off-site landfill. The

filtrate from sludge dewatering

is returned to the PVC Tank for reprocessing through the WWTF. When the filter press is not

operating, the sludge from the primary clarifier underflow is pumped back to the PVC Tank for

reprocessing in the WWTF and sludge discharge

from the secondary clarifieris ceased.

The effluent from the primary clarifieris pumped to four aeration basins (2.0 million gallons

combined volume) that operate in parallel. These basins are aerated to mix the tank contents and to

maintain a minimum operating dissolved oxygen concentration of 1.5 mg/L. Sludge is returned

from the bottom of the secondary clarifier to keep these tanks supplied with an acclimated culture of

bacteria. pH is controlled as needed to maintain an optimumrange forbacterial growth (pH 6.5 to

pH 8.5). The bacteria grown in this tank remove organic compounds with the aid of dissolved

oxygen, ammonia-nitrogen, and phosphorus. In the process of this removal these bacteria also break

away ammonia-nitrogen from organic compounds containing amines (also known as organic

nitrogen compounds). Both biological treatment steps

are illustrated

below. Dissolved

oxygen

needed for biodegradationis provided by the aeration equipment. The two predominantnutrients

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required for biological degradation axe ammonia-nitrogen and phosphorus.

Ammonia-nitrogen is

presentin the wastewater and is formed through degradation of the organic nitrogen in the

compound. Phosphorus is added to the return sludge going back to the aeration tanks.

BiologicalTreatment Reactions

Organic compounds (measured as BOD, Biochemical OxygenDemand)

+

Ammonia-Nitrogen

+

Phosphorus+ Dissolved Oxygen

+

Bacteria yields MoreBacteria (reproduction and growth)

+

Carbon Dioxide

÷

Water

Organic Nitrogen (an organic compound with essentially ammonia-nitrogen attached)

+

Phosphorus+ Dissolved

Oxygen

+

Bacteria yields Organic Compound

+

Ammonia-

Nitrogen...The Organic compound then gets degraded justlike above using some of the

ammonia-nitrogen generated.

The bacteria stayin the aeration tanks about 2.5 days where theydegrade organic compounds and

organic nitrogen. They are thendischarged through aline where they get conditionedwith polymer

to help them

settle better in the secondary clarifier. They settle approximately3 hours in the

secondary clarifier. They are removed continuously offthe bottom of the darifler andsent back to

the aeration tanks to degrademore organic compounds and organicnitrogen. A portion of the

bacteriais removed from the system (termed “sludge wasting”) to control population growth and

keep the average

age of the bacteria (the Mean Cell Residence Time) and Food-To-Mass (F/M) ratio

in an optimal range. The bacteria removed from the system are discharged to the filter press for

sludge dewateringand subsequent off-site disposal in alandfill.

The treatment described includes pretreatment, primary treatment (pH adjustment,

coagulation and

primary clarifier), and secondary treatment (aeration and secondary clarifierwith sludge return). This

treatment is defined by USEPA as the “Best Available Technology Economically Available” for the

Organic Chemicals, Plastics, andSynthetic Fibers industrial category (Code of Federal Regulations

Title 40, Part 414.83, Subpart H).This industrial categoryincludes Noveon and PolyOne. However,

Noveon treats the

wastewater even furtherby discharging the effluent from the secondary clarifier

to a filter to remove additional solids. This additional treatment process is termed tertiary treatment.

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Noveon also filters the water coming out of the Pond to remove solids. These two filtered

wastewater streams combine and discharge through the effluent compliance point that Noveon

monitors for flow and regulated compounds such as

specific organics, BOD and TSS.

The design and operation ofNoveon’s WWTF are compatible with conditions defined by 35 ILL.

Admin. Code 370.920,35 ILL. Admin.

Code 370.1210,

and Ten State Standards

to grow

nitrifying

or ammonia-degradingbacteria as illustrated below in Table

1. However, they do not grow. The

Illinois regulations cited and the Ten State

Standards are design and operating standards that are

intended to promotecomplete nitrification in municipal wastewater treatment facilities. These

standards are intentionally excessive (or conservative) and allow for a significant margin of error in

waste load determinations and operating conditions based on my experience. There are no

Illinois or

Ten State standards

for single stage nitrification of industrial wastewater treatment facilities since the

nature of these wastewaters varies from industry to industry. These industrial designstandards are

developed on a site specific basis usingwastewater characterization data,

treatability testing, and

professional experience.

Nitrifying or ammonia-degrading bacteria are much more sensitive than theb~cteria

that degrade

organic compounds and organic nitrogen. There are compounds presentin the Noveonwastewater

that prevent or inhibit their growth. If the bacteriawere not inhibited and could grow in the aeration

tanks theywould provide ammonia removal in the same tankage as the other bacteriause to provide

organics removal. Consequently, the treatment would be termed single stage nitrification since in the

same tankage (same

stage) both organics removal andammonia removal occur. If you were to grow

these ammonia-degradingbacteria in a system downstream-ofthe secondary clarifier, it would be

called tertiary nitrification. These nitrifying bacteriagrow in the manner described

as

follows:

BiologicalTreatment Reaction

Ammonia-Nitrogen

+

Phosphorus+ Dissolved

Oxygen

+

Alkalinity

+

Bacteria yields More

Bacteria (reproduction and growth)

+

Nitrate-Nitrogen

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Table 1. Comparison ofIllinois Standards,

10

State

Standards, and

Noveon-Henry Plant

Conditions for Single Stage Nitrification

Condition

Illinois

Standarda

Ten State

Standard”

-

Noveon

PlantC

Aeration Tank Loading, lbs BOD/day per

1000 cu ft

~15

~15

14

Aeration Basin Mixed

Liquor DO, mg/L

?~2

?~2

?~2

Aeration Basin Mixed Liquor

pH,

s.u.

7.2 to 8.4

Not Defined

6.8 to 7.2

Sludge Age,

days

?..20

Not Defined

?~40

Aeration Basin Mixed LiquorTemperature, degrees F

?

50

Not Defined

?

80

Aeration Basin Average Hydraulic Residence Time, days

?

0.33

Not Defined

2.5

Aeration Basin F/M Ratio, lbs BOD/day per lb MLVSS

Not Defined

0.05 to 0.10

0.10

ReturnActivated Sludge Flow,

of Ave Influent Flow

15 to 100

50 to 200

100

‘IllinoisAdministrative

Code, Title 35, Subtitle C, Part370, Subpart I, Title 370.920 and Subpart L,

Title 370.1210. Both govern municipal (notindustrial) W\VTF design.

~ Recommended Standards forWastewaterTreatment Facilities, 1997 Edition, Wastewater

Committee of The Great Lakes-Upper Mississippi River Board of State and Provincial Public

Health and Environmental Managers (includes Illinois), Chapter90. These standards are

to

provide guidance in the design of municipal (notindustrial) WWTF design.

C

1999 through 2004.

Applicability of35

ILL.

Admin. Code 304.122: The

provisions of Illinois Title 35, Subtitle C, Part

304, Subpart A, Section

304.122 (35 ILL. Admin. Code 304.122) is stated as

follows:

a)

No effluent from any source which discharges to the Illinois River, The Des Plaines River

downstream of its confluence with the Chicago River System or the Calumet River System,

and whose untreated waste loadis 50,000 or more population

equivalents shall contain more

than 2.5 mg/L of total ammonia nitrogen as N during the months ofApril through October,

or 4 mg/L atother times.

b)

Sources discharging to any of the above waters and whose untreated waste load cannot be

computed on apopulation equivalent basis comparable to that used for municipal waste

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treatment plants andwhose total ammonia nitrogen as N discharge exceeds 45.4 kg/day(100

pounds per day) shall not discharge an effluent of more than 3.0 mg/L of total ammonia

nitrogen as N.

c)

In addition to the effluent standards set forth in subsections (a) and (b) of this Section,

all

sources are subject to Section 304.105.”

Section 304.105 states “In addition to the other requirements of this Part, no effluent shall, alone or

in combination withother sources, cause aviolation of any applicable water qualitystandard.”

Noveon has retained another expert (e.g., Mike Corn, P.E. of AquAeTer) that will testify that

Noveon can andwill comply with water quality standards (section 304.122c) in the Illinois River for

ammonia-nitrogen if theyare allowedto install an effluent diffuser. Noveon has requested IEPA to

grant approval of such installation and is committed to such installation once approval is granted.

An effluent diffuser will more uniformly distribute the discharge of the Noveonin the Illinois

River.

The remainder ofmy testimony is based on Noveon’s compliancewith Section 304.122c.

In my professional opinion, Sections 304.122a and 304.122b do not apply to the Noveon-Henry

Plant discharge

forseveral reasons.

•

The Noveon-Henty Plant untreated waste loadcan be “computed on apopulation

equivalent basis comparable to that used for municipal wastewater treatment plants”.

Consequently, 304.122b does not

apply. In my opinion, the word “comparable” merely

questions whether the data existto express an untreatedwaste load in population equivalents

like one does when either designingor evaluatinga municipal wastewater treatment plant.

The data do

exists and such calculations can be and have been made. The results from such

calculations allow one to put the Noveon-HenryPlant’s untreated waste load in a

perspective others can readily understand (population equivalents). The term “population

equivalent basis” is intendedto put the relative size of an untreated waste load in

perspective. The term was never intended to describe howthe waste load was to be treated

but only the magnitude of the waste load

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•

There are sources that could discharge to ariver for which “apopulation equivalent basis

comparable to that used for municipal waste treatment plants” could not be computed.

These would be discharges for which data could not be gathered to calculate population

equivalents. TEPA usesBOD, TSS, and flow fordetermining population equivalents.

Presumably these discharges would be those forwhich BOD,TSS, and flow could not be

reliably determined. This is not the casewith the Noveon-Henry Plant discharge.

•

An untreated waste loadcan be and has been calculated by myselfand JEPA for the

Noveon-Henry Plant discharge on “a population equivalent basis comparable to that used

for

municipal waste treatment plants”. The correct results from these calculations are stated

below and dearly define the Noveon-Henry Plant discharge

as havingless than 50,000

population equivalents. Consequently, 304.122a does not apply.

•

Since Sections 304.122a

and 304.122b do not apply, the Noveon-I-Ienry Plant is not

required to provide additional effluent ammonia-nitrogen removal. Furthermore, the

As stated above, correct calculations clearly define the Noveon-HenxyPlant discharge

as having less

than 50,000 population equivalents. IEPA has calculated the population equivalents of the

Noveon-Henry Plant for flow and BOD (Response to First Set ofInterrogatories of Noveon, Inc.

to Illinois Environmental Protection Agency,pages 4 and 5) based on data provided in the Baxter

and Woodman-Wastewater Treatment Plant Report datedJune

1994. This report did not present

anydata on the combined untreatedwasteload. The report discussed the wasteload fed from the

equalization tanks to the primary clarifier. However, this wasteload contains wastestreams that are

internal to the WWTF that add flow, BOD, and TSS including primary clarifier sludge

when sludge

dewateringis not occurring, filtrate from sludge dewatering, and backwash water from the tertiary

(secondary clarifier effluent) filter. Even with this addition, IEPA calculated flow and BOD

population equivalents of 916 and 19,412, respectively (page 4). I corrected the population

equivalent calculation for TSS based on data collected by Noveon duringthe period ofJuly 2002

through June 2003. The corrected value was 24,955

as illustrated belowand in Figure

1. This

calculation depends upon

calculating the untreated waste load TSS coming to (not recyclingwithin)

the W~TFfrom all

sources:

PC Tank, PVC Lift Station Discharge which represents the waste load

discharged from the PolyOne production areas, the 213 wastestream waste load before

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pretreatment, the PC Tank discharge, and the C-18 Tank discharge (pretreatment does not change

the flow or TSS of this discharge but does increase its BOD). The TSS dischargedby the combined

Well No.

3

and Storm/UtilityPond discharges are less than 25 percent of the total influent

wasteloadas

illustrated in the Baxter and Woodman report.

•

PVC

Lift Station Discharge Averages(not the PVC Tank Discharge Averages presented in Baxter

andWoodman Report): 133 gptn,

1957 mg/TSS,and 3123

lbs/dayTSS

•

PC

Tank Discharge Averages: 94 gpm,

900

mgfL TSS, and 1015 lbs/day TSS

•

C-18

Tank Discharge Averages: 3.6 gpm,

300

mgfL

TSS,

and

13

lbs/day TSS

•

213 Averages (includedin PVC Tank Discharge data presented in Baxter and Woodman Report):

35 gpm,

2000 mg/L TSS (estimate), and 840 lbs/day

TSS

(estimate)

•

Total:

4991

lbs/dayTSS or apopulation equivalent (PE) of4991

lbs/day TSS divided by

0.20

lbs/day TSS per person(capita) or 24,955

population equivalents. This is much less than PE

of

265,000 calculated

by

IEPA in the Response to First Set of Interrogatories

ofNoveon, Inc.

to Illinois Environmental Protection Agency, pages 4 and

5. The reason for this large

discrepancy is due to recycle solidsincluded in the JEPA calculation. These solids stay within

the WWTF and are not part of the untreatedwaste load for which these calculations are

reserved.

Even though not apart of the IEPA’s definition of “population equivalent”, population equivalents

can also be calculated based on ammonia-nitrogen and Total Kjeldahl Nitrogen (~KN)loads that

are really the thrust of 35 ILL. Admin. Code 304.122. TKN is the summation of ammonia-nitrogen

and organic-nitrogen. The wasteload used to develop all

effluent ammonia-nitrogen reduction

options included average loadings of 385 lbs/day ammonia-nitrogen and 1038 lbs/day Total

Kjeldahl Nitrogen (TKN). Based on population equivalent factors of 0.019 lbs ammonia-nitrogen!

capita per day and0.029 lbs TKN/capita per day (see Wastewater Engineering: Treatment and

Reuse: Metcalf and Eddy, Inc., Fourth Edition, page 182), the Noveon-HenryPlant population

equivalents would be 20,263 and

35,793,

respectively.

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In my professional opinion, all correct and relevant population equivalentcalculations forthe

Noveon-Henry Plant place it under 50,000 population equivalents rendering 35 ILL. Admin. Code

304.122a and 304.122b not applicable.

Highlights ofEffluent Ammonia-Nitrogen Reduction Evaluations atNoveon-Henry Plant

It is my professionalopinion that 35 ilL

Admin. Code 304.122a and 304.122b do not apply.

Consequently, no effluent limitations and therefore no additional effluent ammonia-nitrogen

reductions are required.

The Noveon-Henry Plant currently provides effluent ammonia-nitrogen reduction through source

control and removal

associated with

BOD

removal nutrient requirements. However, in an effort to

resolve disputes with the IEPA, Noveon retained Brown and Caldwefl (where I serve as lead

engineer) to evaluate whether there were any feasible technologies that would provide additional

effluent ammonia-nitrogen reduction.

Both Noveon and Brown and Caidwell have extensively

evaluated additional effluent ammonia-nitrogen reduction over the last 14

years.

All statements made belowrepresent my understanding of the issues and my professional opinion

regarding these issues.

1.0

Unique Characteristics ofthe Noveon-Henry Plant

and

its Associated Wastewaters:

In my professional opinion, several factors make the Noveon-Henry Plant andits associated

wastewaters unique as

it

relates to the Petition for Adjusted Standard. These factors make the

wastewaters at The Noveon-Henry Plant more difficult and more costly to treat than either

municipal wastewaters or most other industrial wastewaters. These factors are listed below.

First, IEPA has reported that there are only three other plants in the country that generate a similar

wastewater. Two of these three plants discharge to a Publicly Owned Treatment Works. Only one of

these plants discharges directly to areceiving water. So, the wastewater is not commonly found.

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Second,

the building block of Noveon’s main product line at the

facility (rubber accelerators) is

MBT (mercaptobenzothiazole). As a building block,

it

is present in numerous wastestreams

throughout the plant sewer system. It is also a well-recognized inhibitor of biological nitriflcation

even at trace levels of 3 ppm as reported by M.L. Hockenbury and C.P.L. Grady in the Journal of

the WaterPollution Control Federation in 1977 (see Exhibit B). This compound is poorly

degradable as you would hope for a rubber-making additive. No consumerwants to buy readily

degradable tires and other rubber products. Because ofits poor degradability, MET is used as an

additive to nitrogen fertilizers to inhibit biological nitrification in the soil so that more ammonia

nitrogen will be available to the crops (seeExhibit B for article publishedin the National Corn

Handbook, February 1992). However, the large use of this inhibiting compound in production atthe

Noveon-Henry Plant make the most widely practiced and least expensive ammonia-nitrogen

removal process

(single stage nitrification)

unavailable atthe Noveon-HenryPlant. MET removal is

provided in the WWTF Noveon-Henry Plant, just not to the trace levels required to initiate

biological nitrification. Consequently, atypicaland expensive processes would be required to reduce

effluent ammonia-nitrogen concentrations.

Third, the Noveon-Henry Plant and PolyOne Plant contain wastestreams that require pretreatment

aheadof the onsite biological treatment plant to preventprocess upsets and non-compliance with

effluent BOD andTSS limits. Consequently, there is an inherent unreliability with any biological

treatment process used onsite whether it

is

used for BOD removal or nitrification.

Fourth, the Noveon wastewater contains several degradable organic nitrogen compounds such

as

tertiary butyl amine. When these compounds are degraded, theyrelease ammonia-nitrogen.

Consequently,

the effluent ammonia-nitrogen concentration increase as the presence of these

compounds increase in the influent wastewater and as these compounds are more thoroughly

biodegraded. This explains why the influent ammonia-nitrogen concentration at the Noveon-Henry

Plant is much less than the effluent concentration (less than40 mg/L versus greater than 80 mg/L).

Consequently, the majority of the effluent ammonia-nitrogen atThe Noveon-Henry Plant is due to

thorough biological treatment oforganic compounds.

Fifth, the compounds presentin the Noveon-HenryPlant wastewater make oxygen transfer into this

wastewater about half as efficient as municipal wastewater as measured

by a parameter known as

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“alpha”. Alpha is the ratio of oxygen transfer in wastewater divided by the oxygen transfer in

tapwater. In municipal wastewater this alphavalue for fine bubble diffused aeration is typically

0.60 versus

the 0.35 measured in the Noveon-Henry Plant wastewater in 1987 by Gerry Shell

Consequently, the Noveon-Henry Plant has to use about twice the horsepower to transfer the same

amount of oxygen atmunicipal wastewater treatment plants. Furthermore, thisincreased power has

to be accompanied by increased aeration tankage to keep operatingpower levelsin a reasonable

range.

Sixth,the Noveon-I-lenry Plant wastewater is lightly buffered. Consequently, if biological

nitriflcation could be implemented with inhibitor control,the majority of alkalinity would have to be

added whereas in biological nitrificationof municipal wastewater the majority (lf not all) of the

alkalinity required is present in the wastewater.

Eighth, the Noveon-Henxy Plant does not have any additional appreciable power available atthe

WWTF. Any significant additional power required at the WWTF would require installation of a new

motor control center and installation of anew power line to a substation located approximately

0.5 milesaway. Consequently, any WWTF upgrade (regardless of magnitude) to address effluent

ammonia-nitrogen reduction will require a significant cost ofpower delivery.

2.0

Plant

During the last

14 years, Noveon andBrown andCaidwell haveconducted extensively evaluated

whether therewere any feasible technologies that wouldprovide additional effluent ammonia-

nitrogen reduction at the Noveon-HenryPlant. These evaluations have consisted ofliterature

review, consultationwith additional experts, laboratory-scale treatment investigations, full-scale

operations and capital enhancements, and full-scale plant trial investigations. Many of these

evaluations were based on results of prior evaluations in an attempt to continue to build on findings

ofprior evaluations. In

my professional opinion, there havebeen “norelevant stones left unturned”.

The significant evaluations in which

1 have participated are summarized below.

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2.1

Single Stage Nitrification, Powdered Activated Carbon Addition, EffluentIon

Exchange

and

Tertiary

(Effluent) Nitrification

When I first got involved atthe Noveon-Henry Plant in 1989, the focuswas on developinga

strategy for achieving

consistent effluent BOD compliance. Brown and

Caldwefl conducted

continuous flow treatability testing, that I designed and oversaw, that indicated this compliance

could be achieved with pretreatment of one major wastestream

(C-I 8). During

the course of the

treatabillty studies,

we noticed that the WWTF would discharge elevated

concentrations of

an-unonia-nitrogen while providing

excellentBOD removal. Despite carefully controlled conditions

of F/M, MCRT, pH, temperature

and

DO that should prompt

biological nitrification, none was

observed. This indicated that MET and possibly other bio-inhibitors were present in the influent at

sufficient levels to prevent biological nitriflcation. Batch testing was conducted in early 1989 to

determine ifpowdered activated carbon (PACt)

could be added to remove these

inhibitors and allow

biological nitrification. Furthermore, batch testing also evaluated

selective ion exchange treatment

(dlinoptilolite)

of the effluent,

and tertiary (effluent) nitrification of the effluent. This work indicated

that an untenable, large dose of PAC would be required to allow single stage nitrification

(5000mg/L or 17 tons/day). Because of this finding (untenable carbon usage) and

the

certainty of

fouling problems, no furtherconsideration was given to carbon treatment

.

This

work also indicated

that even the most appropriate ion exchange was not

selective for ammonia-nitrogen removal due to

the other competing cations in the wastewater (approximately 100 pounds resin required to remove

1 pound ofammonia-nitrogen). Lastly, thiswork suggested that the effluent could be biologically

nitrifled with yet another or tertiary treatment unit. Consequently,

subsequent evaluations

considered more thoroughly tertiary nitrification.

2.2

Further Evaluation of

Tertiary

Nitrification

andPretreatment with Single Stage

Nitrification

Based on these results, Noveon’s corporate Research and Development group initiated a continuous

flow treatability study that focused on tertiary nitrificationwith alkalinity addition. This work was

conducted over about a 6 month period using fixed film biological nitrification and secondary

clarifier effluent samples that were collected monthly. The work indicated that tertiary nitrification

could be accomplishedand low discharge ammonia-nitrogen concentrations

(less than 6 mg/L)

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could be achieved with alkalinity addition and effective performance of upstream treatment

processes. Therewere legitimate concerns about how reliably this process would have performed

under the daily variability of secondaryclarifier effluent quality.

Brown and Caldwell also initiated a series of batch treatabilitytests that I designed and oversaw.

This testing was to identify if available technologies could be used to remove the bio-inhibitors

presentin the influent wastewater to the extent that the most widely practiced and least expensive

ammonia-nitrogen removal process (singie stage nitrification) could be employed. These treatabillty

tests evaluated hydrogen peroxide treatment, clay absorption,

and precipitation. However, the rate of

biological nitriflcation was

slower than would be expected for an uninhibited

system indicating that

bio-inhibitors were still presentin the effluent from the treatment plant This work indicated that

precipitation and filtration of the Noveonwastewater atpH 2 would allow single stage nitrification

to proceed. However, this pretreatmentwould require significant acid addition to lower the

wastewater pH from pH

10 to pH 2 and then significant alkali addition to increase the pH from

Ph 2 to pH 7 forbiological treatment The precipitant from the pH 2 pretreatment was

analyzed and

found to be predominantly

MET

(a known nitrificationinhibitor).

2.3

Further Evaluation

of Pretreatment (p112 Precipitation

and

Solvent Extraction) and

Single Stage Nitrification

Based on results of the work described above, Brown and Caldwell conducted a continuous flow

treatability study, which I designed and oversaw, to evaluate pH 2 pretreatment of the PC

wastewater and singie stage nitrification. This studyindicated that singie stage nitrification could be

achieved with this pretreatment. The rate of nitrificationwas inhibited indicating that some

bio-inhibitors still remained in the combined influent. Effluent

ammonia-nitrogen concentrations

from this process varied from I mg/L to 20 mg/L, indicating a variation in remaininginfluent

bio-inhibitor concentrations. It was concluded that this pretreatment process would support single

stage nitrification. However, effluent ammonia-nitrogen concentrations

would not consistently

achieve those limited by 35 ILL. Admin. Code 304.I22a or 304.122b.

During this same period

of time, Noveon investigated a process used in Germany for MET

recovery. This process used solvent extraction. Results of this investigation reportedly indicated that

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the process would pose safety concerns (potential forexplosions) and would also be costprohibitive

to implement at the Henry Plant (reportedlygreater than $10 million).

2.4

Assessmentof WWTF for Compliance with Conventional Design for Single Stage

Nitrification 35

ILL. Admin.

Code

370.1210 and

370.920

Noveon retained Baxter andWoodmanin

1994 to review the WWTF for compliance with

the

Illinois design standards for single stage nitriflcation of municipal wastewaters. These standards axe

intentionally excessive (or conservative) and allow for a significant margin

of

error in waste load

determinations andoperating conditions based on my experience. There are no Illinois design

standards for single stage nitriflcation of industrial wastewaters.

These industrial design standards

are developed on asite specific basis usingwastewater characterization data, treatability testing,

and

professional experience.

The reviewby Baxter and Woodmanindicated the WWTF would comply with

the

municipal

wastewater standardswith the addition of about

65 percent more aeration tankage. I was convinced

that the WWTF would not provide single

stage nitrificationwith this additional aeration tankage.

However, Noveon expanded the aeration tankage in 1998 by

100 percent to provide greater aeration

capacity and greater treatment plant flexibility. This addition put the WWTF in full compliance with

35 ILL. Admin. Code 370.1210 and 370.920 and Ten State

Standards (which includes Illinois) for

single stage nitriflcationand yet the WWTF did not exhibit anynitrification. The reason nitrification

was not achieved was not due to a lack of equipment, but rather the presence of bio-inhibition.

2.5

Alternative Bacteria

IEPA had conducted aliterature search and found an artide that seemed to imply that special

bacteria could be grown in the Noveon-Flenry Plant that would both degrade the difficult

compounds (such as morpholine) and remove ammonia-nitrogen atthe same time.

I explained to

IEPA that these were not the findings of this article. However, IEPA was persistent that these

bacteria could achieve both types of degradation (morpholine and ammonia-nitrogen).

Consequently, Noveon brought in the author of this article from England (Dr. Jeremy Knapp).

Dr. Knapp reviewed the Noveon-Henry Plant operation. He then explained that the bacteria that he

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wrote about were already presentin the Noveon-HenryPlant based on morpholine removal data he

had reviewed and that the conditions present in the Noveon-Henry Plant were suitable for

maintaining aculture of these bacteria. He further explained that these bacteria do not provide

nitnification. He also explained that the Noveon-HenryPlant provided

all the right conditions for

single stage nitrificationifbio-inhibiting compounds were not present

Noveon on

several occasions has tried adding specialty bacteria to removedifficult to degrade

compounds. During these same periods, Noveon has added nitrifying bacteria from the Peoria

P01W. In no instance has Noveonbeen able to initiate nitrification. This indicates that the lack of

nitrificationis due to inhibitors that are not degraded within the confines of the Noveon-Henry

Plant evenwith special bacteria addition. Furthermore, this Plant offers the biological treatment

opportunity that is required by Ten State Standards and 35

ILL. Admin. Code 370.1210 and 370.920

for single stage nitrification.

2.6

Numerous Occasions

of

Seeding Plant with Nitrii~ting

Bacteria

The Noveon-Henry Plant has been in compliance since 1998 with Ten State

Standards and 35

ILL.

Admin. Code 370.1210 and 370.920for single

stage nitrification. Since this time, Noveon has added

on numerous occasions bacteria from other WWTF that are activelynitrifying. These additions were

intended to improve the Noveon-HenryPlant WWTF performance. Yet, in no case has nitrification

occurred at the Noveon-Henry Plant despite optimum conditions of MCRT (greater than 30 days),

temperature (28 to 32 degrees C), pH (6.8 to

7.5), DO (greater than 2 mg/L).

Again,

it

is my

professional opinion that this is due to the presence of bio-inhibitingcompounds in the influent.

2.7

Full-Scale Plant Trial

of

Alkaline Air Stripping to Achieve Effluent Anirnonia-

Nitrogen Reduction

The Noveon-Henry Plant conducted a full-scale trial of alkaline air stripping of the combined

influent. This required Noveon to

set up an interim pumping system, caustic addition system, and

acid addition system. This interim system diverted all primary clarifier effluent (approximately

560 gallons per minute) to an aeration basin that had been set

aside for this testing.

Caustic was

added to the aeration basin to maintain a target pH value of 10.5. A surface aerator was placed in

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this basin and operated to assistin air stripping. Effluent from this tank was diverted to a blend tank

where the pH was

lowered. The blend tank contents were thenpumped to the ~ther three aeration

basins forbiological treatment. This treatment did demonstrate a modest reduction in effluent

ammonia-nitrogen (less than 20 percent). This reductionwas low, in my opinion, due primarily to

the fact that the majority of the effluent ammonia-nitrogen is formed during biological treatment.

Secondly, the pH control method was unable to consistently keep the tankcontents at or above

pH 10.5.

2.8

Full-Scale Trial of Pretreatment and Single StageNitrification

Noveon environmental staffconducted a literature search and found an article that indicated that

MET could be co-precipitatedwith ferric hydroxide at an elevated pH (seeExhibit B). The

article

indicated that significant removal could be accomplished at pH 4.5 versus the pH 2 pretreatment

evaluated by Brown and Caldwell. Noveon conducted a full-scale trial

of

this pretreatment system in

hopes of achievingsingle stage nitrification.

I reviewed the article, believed their was a likelihood

of

success in this trial, helped design the trial conduct, reviewed data from the trial and witnessed this

trialin progress. The trial involved Noveon installingan interim precipitation system and separate

sludge dewatering system to treat and segregate pretreatment byproducts (sludge and filtrate from

sludge dewatering). The entire PC wastewater discharge (120 gpm) was routed

through this system

involving ferric chloride addition to lower the PC Tank wastewater to pH 4.5. The pH adjusted

water was allowed to separate in interim claniflers. The treated wastewater was transferred usingan

interim pumping system to the existingprimary treatment system. The precipitated sludge was

dewatered using an interim filter press with precoat addition

system. The filtrate from sludge

dewatering was routed back to the pretreatment system. The pretreatment system was operatedfor

months and did demonstrate significant MBT removal

(greater than 50 percent). At the end of this

operatingperiod, Noveon brought in a tanker load (5000 gallons) of bacteria from a plant in Indiana

that had a high population ofactive nitrifyingbacteria. The bacteria were added to the aeration

basins. The pretreatment system continued to operate while Noveon checked

for signs of

nitrification in the activated sludge system. The activated sludge system was operated under adequate

DO, pH, MCRT and alkalinitycontrol to prompt nitrification. No nitrification occurred despite this

large investment of resources (greater than $100,000) and time (greater than 4 months). Itis my

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opinion that nitrification did not occur because of the continued presence of bio-inbibiting

compounds in the influent (MBT and likely others).

2.9

Consideration ofOther Lesser Known Technologies

Another consultant (Ecology and Environment,

mc)

was retained to review the work of Brown and

Caldwell for Noveon. This consultant believed that all feasible technologies had been considered for

effluent ammonia-nitrogen reduction excluding ozonation. A conceptual level design and cost

estimate was developed forthis treatment process.The processwould presumably achieve a

98 percent reduction in effluent ammonia-nitrogen but at a present worth cost of $20.32 million

(almost twice the cost of any other process considered). This processwould also significantly

increase the effluent total dissolved salt concentration due to the caustic addition required to

neutralize the acid generated from this process.Additionally, a significant substation upgrade would

be required to deliver the additional power consumed (equivalentto approximately 3500 hp

demand).

I discovered in 2003 a company in Memphis, Tennessee that had apatented membrane that

selectively

separatedammonia-nitrogen from wastewater containing little other constituents besides

ammonia-nitrogen. This membrane was tested to remove ammonia-nitrogen from alandfill leachate

and groundwater stream that was less concentrated in other constituents than the Noveon

wastewater. The company conduded after actual testing that the membrane would not be suitable

for treating the leachate

and groundwater stream due to interference caused by other compounds

presentin the wastestrearn. Consequently, I did not further pursue use of this membrane at the

Noveon-Henry Plantfor effluent ammonia-nitrogen reduction.

2.10

Comparative Performance and Costs of

Reduction Processes

After approximately 14 years of extensive evaluations

by Noveonand Brownand Caidwell,

all

applicable treatment processes, in my professional opinion, have been considered for effluent

ammonia-nitrogen

removal. Treatment processes considered went beyond those included in the

USEPA Process Design Manual: Nitrogen Control (EPA 625R93010). No stone has gone unturned.

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The proven treatment processes described above have beendeveloped by me and support staffwell

enough to accomplish the following.

•

predict potential effluent ammonia-nitrogen reduction,

•

understand the pros andcons,

•

develop conceptual level designs for their application, and

•

develop conceptual level design cost estimates (capital, annual, and presentworth costs) for

these treatment aiternatives to within

30 percent accuracy usingavailableinfluent waste load

data.

The proven treatment processes that were evaluated are listed below.

•

Alkalineair stripping (air stripping atpH 10.5) of PC Tank contents with off-gas collection

and treatment. Noveon believed this off-gas collection andtreatment would be required to

comply with air quality regulations. At high pH ammonia-nitrogen exists as agas dissolved in

liquid and can be removed from the liquid by air stripping.

•

Alkaline air stripping of

PVC

Tank contents.

•

Alkaline air stripping

of

secondary clarifier effluent.

•

Struvite precipitation of combined influent prior to primary clarification. Ammonia-nitrogen

can be precipitated as NFI4MgPO4(H2O)6.

•

Breakpoint chlorination of secondary clarifier effluent. The addition ofchlorine converts

ammonia-nitrogen to nitrogen gas that exits the liquid to the atmospherewithout the need

forair stripping.

•

Nitrification of PVC Tank wastewater (non-PC wastewaters).

Nitrificatiori is a process by

which bacteria convert ammonia-nitrogen to nitrate-nitrogen. The bacteria consume large

amounts ofoxygen

(4.6 lbs oxygen/lb ammonia-nitrogen

removed) and alkalinity (7.14lbs

alkalinity/lb ammonia-nitrogen removed).

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•

Nitrification of the combined wastewater. This process would require pretreatment of the

PC wastewater to remove

bio-inhibitors.

•

Nitrification of secondary darifler effluent

(tertiary thtrification).

•

Ion exchange treatment of the final effluent. Ion exchange is a process where another cation

(e.g., sodium (Na4) or hydrogen (H4) is released from a resin into the water so another

cation (NH44)

can be removed from the water.

The treatment process evaluation described above is briefly summarized in Exhibits C, D, and E.

This evaluation established that the processoffering the lowestpresentworth costfor reducing

effluent ammonia-nitrogen was

alkaline stripping of the PC Tank contents ($2.31

million). This

alternative howeverwould only provide a 27 percent reduction in effluent ammonia-nitrogen. If

35 ILL. Admin.

Code 304.122b was applicable, and I strongly believe that itis not, the average

effluent ammonia-nitrogen would have to be reducedby 98 percent (135 mg/L reduced to 3 mg/L).

Under peak effluent conditions, the effluent ammonianitrogen reduction would have to exceed

98 percent. The process offering the lowest present worth

cost thatwould be capable of

meeting the

98 percent reduction requirement was ion exchange ($5.07 million). However, this process would be

complicated to operate, would generate awaste byproduct (liquid ammonium chloride) requiring

offsite disposal and would be prone to foulingby

scaling and bacterial growth.The next least

expensive process capable of achieving 98 percent reduction was breakpoint chlorination

($9.73 million). However, this processposes significant safety and site securityconcerns

(chlorine

gas is extremelyhazardous), would significantly increase effluent total dissolved salt (IDS)

concentrations and therefore would increase effluent aquatic toxicity, and could generate chlorinated

organics that could in turnincrease

effluent aquatic toxicity. Lastly, the nextleast expensiveprocess

capable of achieving 98 percent reduction was nitrification of the combined wastestream

as a single

stage process ($11.71 million) or as a tertiary process ($11.41 million). Both processes would result

in an increase in effluent TDS and both processes would provide variable performance based on the

variability of influent bio-inhibiting compounds. At times, neither process would comply with the

requirements of 35

ILL. Admin. Code 304.122a and 304.122b (even those these are not

applicable to

the Noveon-Henry Plant).

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2.11

Evaluation of

Alternative

Methods ofEffluent Ammonia-Nitrogen Measurement

Numerous treatment processes were evaluated to reduce effluent ammonia-nitrogen.

Effluent

ammonia-nitrogen was reduced but with greater difficulty in many cases than expected. This

difficultymade me question whether there could be a fundamental error in the measurement of

effluent ammonia-nitrogen. The method used by the IEPA laboratory andthe outsidelaboratory

used by the Noveon-Henry Plant for effluent compliancemonitoringwere the same. Both

laboratories used the ion selective probe method.This method is recognized by USEPAas

registering artificially elevated values in the presence of organicnitrogen compounds. These

compounds are likely to be present in the Noveon-Henry Plant effluent. Noveon, at my suggestion,

conducted a testing program where the secondary clarifier effluent was analyzed using the historical

method without distillation, the historical method with distillation, andthe phenate method -with

distillation. All threemethods are approved by USEPA. The last method mentioned was the method

least prone to interference by organic nitrogen.

Results of this test method indicated a slightly lower

value for effluent ammonia-nitrogen with distillation andwith the phenate method. However, the

average ofall values was within

15 percent regardless of the method selected. This finding indicated

the historical effluent ammonia-nitrogen concentrations were reasonably accurate and that the

historical method could continue to be used with reasonable accuracy to monitor effluent

ammonia-nitrogen concentrations. The effluent concentrations measured throughout all treatment

evaluations could be considered reasonably accurate. Effluent ammonia-nitrogen reductionhad

indeed been as difficult to achieve as measured.

3.0

OTHER

ISSUES RAISED

BY IEPA

3.1

GAC Treatment of Influent

GAC (granular activated carbon) has been used to remove inhibitors from wastewaters and one of

the inhibitors (possibly the predominateinhibitor) is removable by GAC. So, at face value this

suggestion appears reasonable. However,

several factors render it non-practical. First, the influent

does contain some organics that are readily degradable such as isopropyl alcohol and ethanol. These

readily degradable organics would cause bacteria to grow on the GAC column and slime over the

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GAC pore spaces rendering the GAC unavailable for removal ofinhibitors. Second, the inhibitors

are not the only compounds in the influent that would be adsorbed by the GAC prior to being

slimed

over.

Recall that 5000 mg/L PAC or

17 tons/day was required to prompt nitrification.

Consequently, the GAC usage (evenif sliming were not an issue) would be excessive in the order of

tons/day.

3.2

Implication that

Noveon has not implemented any Ammonia-NitrogenRemoval

Measures

Noveon has installed in-plant recovery devices and instituted pollution prevention plans to minimize

the discharge of organic nitrogen (such as tertiary butyl amine)

to the WWTF

which have been

converted to ammonia-nitrogen through biological treatmenthad such recovery not been provided.

Noveonhas evenbeen recognized by the State of Illinois for progress in pollution prevention

(Annual Govemor’s Award for Pollution Prevention in 1999,2002, and 2003 with Governor’s

Citation Award for Pollution Prevention in 1998). Second, the Noveon-Henry Plant has consistently

removed ammonia-nitrogen through its WWTF as a nutrient required forBOD removal

(approximately 0.04 lbs ammonia-nitrogen removed/lb BOD removed). BOD-removing bacteria

are more tolerantof inhibitors than are nitrifyingbacteria.Without this BOD removal, Noveon

would discharge approximatelyan additional 20 mg/L ammonia-nitrogenin the final effluent. The

Noveonwastewater just contains more ammonia-nitrogen than required as a nutrient for BOD

removal. Lastly, it should be noted that Noveon has exerted significant effort in conducting two

full-scale trials in an attempt to demonstrate a WWTF modification that would provide effluent

ammonia-nitrogen reduction. One trial provided less than a20 percent reduction and the other trial

provided no reduction.

3.3

Attempt to Compare Cost ofAmmonia-Nitrogen Removal between Noveon and

Others

As described in I above, the Noveon-J-lenry Plant has several unique features that render its cost of

providing ammonia-nitrogen removal more expensive than others. The comparisons made by the

JEPA considered only the capital costs of single

stage nitrification. Operations and maintenance

(annual) costs were not included in the comparison.

However, as noted in Exhibit C,

these annual

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costs for Noveon would be significant The

facilities used in the comparisons by the IEPA were

likely required to add little or no chemicals to achieve nitrificationwhereas the Noveon-Henry Plant

would be required to spend $788,000 annually on

chemicals alone. This high chemical costis due to

chemicals required for the pH 2 pretreatmentprocess (acid to lower the pFI and caustic to raise the

pH for biological treatment) and caustic required providing the alkplinity consumed in nitrification.

This yields a present worth chemical only costof $5.29 millionexcluded from the cost comparisons

made by JEPA (based on a 10 year project life). IEPA suggested that a 20 yearproject life would be

more representative. Under this project life, the presentworth cost of chemicals would increase to

$7.73million. Eitherway, this is a significant omissionin cost comparisons. In addition, this does

not include the added operating costthat Noveon would haverelated to pretreatment system

operations andincreased aeration horsepower. Only presentworth costcomparisons are meaningful

when there is a significant difference in operating costs

as is the case here. In my

professional

opinion, thereis no doubt that single stage nitrification at the Noveon-HenryPlant would be far

more expensive on apresentworth basis than any facility the JEPA used in its comparisons.

It is likely that apresentworth cost comparison of these facilities would reveal that the cost of

ammonia-nitrogen

removal is less than $0.20/lb (the surcharge costimposed by the Knoxville

Utility

Board on ammonia-nitrogenis $0.12/pound of ammonia-nitrogen) for the POTWs. The present

worth cost for Noveon to implement

single stage nitrificationis $3.60/lb to $2.32/lb (depending on

whether a 10 year or 20 year project life is assumed,respectively) of ammonia-nitrogen reduced or

18 to

12

times the costfor facilities of the type described by the JEPA.

4.0

INCREMENTAL

COST OF

PROVIDING EFFLUENT AMMONIA-NITROGEN

REDUCTION

The IEPA suggested that they would be more supportive of Noveon’s Petition for Adjusted

Standard ifsome effluent ammonia-nitrogen removal were provided. Itis my professional opinion

that JEPA has failed to recognize that the Noveon-HenryPlant already provides effluent

ammonia-nitrogen reduction through source control practices and ammonia-nitrogen removal

accomplishedin BOD removal. Nevertheless, Noveon requested that Brown and Caidwell calculate

the cost of incrementally providing effluent ammonia-nitrogen reduction. I personally developed the

basis for this cost analysis and reviewed and approved the process by which

theywere calculated. In

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some cases incremental effluent ammonia-nitrogen would be accomplished by treating only a

portionof the wastewater. In other cases, it would be accomplished by sizing the treamient vessel to

only provide partial treatment. The results of this exercise are summarizedin Exhibit D.

These results indicated that even a 25 percent reductionin effluent ammonia-nitrogen would have a

presentworth cost of $1.8 million

to $3.9

million depending upon the treatment process selected.

Moreimportantly, the

25 percent reduction would not

achieve compliance with 35

ILL. Admin.

Code 304.122b assuming it applied and

it

does not apply.

5.0

SUMMARY

The Noveon—Henry Plant currentlyprovides effluent ammonia-nitrogen reduction through source

control and removal associated with BOD removal nutrient requirements. In my professional

opinion, any furtherreduction in effluent ammonia-nitrogen is not required by

35 ILL.Admin.

Code 304.122 ifIEPA approves Noveon’s installationof an effluent diffuser. This diffuser will allow

a more uniform distribution of the effluent from the WW1Pin the Illinois River andwill allow

water quality criteria to be maintained. Both 304.122a and 304.122b do not apply because the

Noveon-Henry Plant clearly has an untreatedwasteload with a population equivalent less than

50,000 based on

all relevant calculations.

Consequently, no effluent limitations and therefore no additional effluent ammonia-nitrogen

reductions are required by this Code.

Extensive efforts have been made by Noveon and its consultants over the last

14 years in examining

effluent ammonia-nitrogen reductions. These extensive improvements

and studies havenot been

taken to seek compliance with 35 ILL. Admin. Code 304.122. They have been undertaken in good

faith to resolvedisputes with the IEPA and to evaluate whether there were any feasible technologies

that would provide additional effluent ammonia-nitrogen reduction.

The

findings of effluent ammonia-nitrogen reduction efforts have been shared with IEPA and are

summarized inExhibits C, D, and E. These findings show the following

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•

The Noveon-Henry Plant has atleast eight unique characteristics that render it unusually

difficult andexpensive to achieve any further ammonia-nitrogen removal.

•

Every proven treatment process for effluent ammonia-nitrogen reduction has been

considered by the Noveon-HenryPlant, even onethat was in the developmental stages.

•

Noveonhas had several consultants evaluate effluent ammonia-nitrogen removal. These

haveincluded awell-respected Illinois firm, a nationally-recognized engineering firm, and a

research professor from England.

•

No treatment technologywas found by IEPA or anyof these consultants that could provide

significant effluent ammonia-nitrogen reduction (greater than 50 percent) for a present

worth cost of less than $5.0 million. Even a 25 percent effluent ammonia-nitrogen reduction

had apresent worth

cost of at least $1.8

million. Neitherof these removals is required to

comply ‘with 35 ILL. Admin.

Code 304.122a or

304.122b since they are not applicable to the

Noveon-I-lenry Plant.

•

The present worthcost of installing single stage nitrification, like facilities IEPA used in cost

comparisons, was $11.7 million. This costwhen compared to the surcharge cost imposed by

a POTW on ammonia-nitrogen indicated that the Noveon-Henry Plant costs for

ammonia-nitrogen removal would be

18

times greater than that fora POTW. This cost

difference was not revealed in IEPA analysis due alack of consideration given to

disproportionate operating costs.

In my professional opinion, Noveon has gone far beyond that which Illinois regulations require in

evaluating effluent ammonia-nitrogen removal.

Good

faith and awillingness to work with IEPA

have been demonstrated. Fourteen

years and considerable resources have been applied in effort to

find an agreeable position with IEPA. Such an agreementwas not reached. Noveon’s Petition for

Adjusted Standard is reasonable and should be supported by the Board in conformity with Illinois

regulations.

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CERTIFICATE

OF SERVICE

The

undersigned

certifies

that a

copy of

the

foregoing

Notice

of

Filing

and Written

Expert Testimony

of Houston Flippinwas

filed by

hand

delivery with

the

Clerk

of the

Illinois

Pollution

Control Board

and served upon the

parties

to

whom said Notice

is

directed by

first

class

mail,

postage prepaid, by

depositing

in

the U.S.

Mail

at

191

N. Wacker

Drive,

Chicago,

Illinois

on Friday,

February 6, 2004 and facsimile.

CHO1/12336513.1

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m

0~

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EXHIBIT A

RESUME

OF T. HOUSTON FLIPPIN, P.E., DEE

---

T.

Houston

Flippin,

P.E.,

DEE

Assignment

Experience

Summary

Capacity Evaluation

Houston Flippin has 20

years

of experience in

industrial and municipal

Education

wastewatermanagement.

Mr. Flippin is particularly adept at maximizing

M.S.,

Environrnenta~

and Water

treatment process

performance.

This is due

to

years

of conducting,

vdftu•~”1984

evaluating,

and

developing

full-scaleprocess design

and operatingguidelines

from bench-, pilot- and

full-scale wastewatertreatment studies. These

E.,

Civ

and Environmental

studies have evaluated both biological

and

physical/chemical processes for

Vanderbilt

University,

1982

treating waters, wastewaters,

and

sludges

laden

with

conventional pollutants,

Registration

priority pollutants,

and

aquatic toxicants.

Mr. Flippin has used

this

Professional

Engineer.

Tennessee,

experience to bothdevelop treatmentcost savings

(capital

and operating)

Illinois, Kentucky, and Michigan

while

maintaining

reliable effluent

compliance and to negotiate more

Diplomate:

American Academy of

reasonable effluent

limits. His

“hands

on”

experience

and his

talent for

Environmental Engineers

communication

has

made

him a

frequent

workshop lecture, client

staff

Experience

trainer, and negotiator.

Recentwork on

the

industrial side has involved

20

years

developing innovative, reliable and cost-effective pretreatment processes

Joined

Firm

and

minimizing upgrade costs of treatmentlagoon systems. Recent work on

1984

the municipal side

has involved rerating capacities of POTWs using site-

Relevant

Expertise

specific data, developing cost saving actions for aeration and sludge

•

Developing

sfte

specific operating

handling,

and

developing staff reorganization plans to enhance productivity.

guidelines and

treatment

Mr. Flippin

also

has

experience in potable water treatment, stormwater

capacibes.

permitting, wasteload surveys, and waste minimization.

I

Developing cost savings for

________________________________________________________________________________

treatment

plants.

•

Organic Chemicals, Herbicides and Pesticides

Process Design, Start-up Assistance and Operator Training,

Ciba-

Geigy Corporation

LeadEngineer andAutbor.

Responsible for an on-site

treatability studies,

process design development,

and final report for the treatment of

wastewaters discharged from Ciba-Geigy Corporation’s largest U.S. organic

chemicals manufacturing complex including pesticides. The project began

by evaluatingconversion of the existing aeratedlagoon system to activated

sludge. This conversionwas necessaryto meet effluent requirements under

higher

loading conditions

and

to meet RCRA closure requirements of on-

site surface impoundments.

This

evaluationinvolved

an activated sludge

treatability study evaluatingthe impact of varying totaldissolved solids

concentrations (0.5 percent to 2.5 percent),

temperatures (8°Cto 20°C)

and

RCRA regulated

stream discharge contributions. A process design for the

aerated lagoon/activated sludge

conversionwas developed, presented, and

implemented.

Mr. Flippin developed materials for

and

assisted in the

operator training course which preceded startup of the activated sludge

plant.A follow-up treatability study was conducted

and focused

on

TKN,

TOC, acute

toxicity

and color reduction through the use of PACT®

treatment as

compared to

tertiary

GAC treatment.

Special batch treatability

BROWN

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T. Houston

Flippin,

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testing evaluated alternative source control methods for a

highly

colored

wastestream. A process design was developed to meet revised treatment

objectives, a final report was issued, and a new WWTF was constructed.

Startup

assistance

and operator

training were provided for

both WWTFs.

Process Design, Rhodia, Mount Pleasant, Tennessee

LeadEngineer andAutbor.

Responsible for an

treatability studies, process

design development, and

final report for the treatment of herbicide

wastewaters. Treatments evaluated impact of

photolytic decomposition,

carbon adsorption,

and

macroreticular resins. Solutionimplemented

included minor treatmentand recycleof waters.

Site converted to a nearly

zero discharge operation.

POTW

Impact and Discharge Negotiations, American Cyanamid,

Barcoloneta, Puerto Rico

LeadEngineer andAutbor.

Responsible for an treatability studies that

evaluated impact of herbicide

and

pesticide wastestreams on

POTW.

Testing indicated no adverse impact on BOD removal, nitrification,

and

sludge

quality

at the desired discharge rates.

Results of testing were used to

negotiate allowed discharges of these wastestreams to the

POTW

without

pretreatment.

WWTF

Troubleshooting, Zeneca Fine Chemicals, Mount Pleasant,

Tennessee

LeadEngineer andAuthor.

Responsible for treatability studies that evaluated

impact ofvarious organicchemical, herbicide and pesticide wastestreams on

site’s biological wastewater treatment facility (WWTF). Developed approach

for screening impact of new wastestreams on the WWTF.

Prescribed

maximum allowabledischarge

rates of each process waststream to prevent

upset of

the WWTF.

Pulp and Paper

Comprehensive WastewaterManagement Plan, Chesapeake

Corporation, West Point, Virginia

Lead Engineer, Field Team Manager,

andAuthor.

Developed a comprehensive

wastewatermanagement plan for a Chesapeake Corporation

1,800

tpd

integrated mill.

Wastewater characterizationstudies defined sources and

distribution ofwaxes through the pulping and paper making process, the

impact of secondary fiber production on

W.’F

solids management, the

impact of bleachingprocess chlorine substitution on influent wasteloads,

effect of separate

and

combined settling of pulp mill and paper mill

wastewaters, and impact of various equalization basin sizes

and

modes of

operation on influent load dampening.

Batch treatability tests evaluated

alternative primary clarification schemes,

alternative site applications of

dissolved

air flotation (DAF) for

wax

removaland solids recovery, impact

of CO2 stripping/coagulation and flocculation on pure oxygen activated

sludge settleability

andimpact ofsecondary fiber on activated sludge settling

properties.

Continuous flow treatability studies evaluated the

effects of

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T. Houston Flippin, P.E.,

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secondary fiber production, secondary fiber wastestream DAF

pretreatment, aeration basin

temperatures, slimicide

loadings and bleaching

plant

chlorine substitution

on pure oxygen activated sludge plant

performance (particularly

sludge

settleability).

The continuous flow

treatability studies also involved evaluation of several types

of biological

selectors to control filamentous sludge

bulldn~aerobic, two-stage aerobic,

anoxic/anaerobic, and extended anoxic/anaerobic.

Elements of

this project

were presented by Mr. Flippin atthe

1992 TAPPI Environmental

Conference.

Lagoon Modeling and Upgrade Evaluation, Confidential Client,

Midwest

LeadEngineer.

Developed alternative upgrade measures

for a wastewater

treatment lagoon systemto accommodate increased wasteload

while

not

exhibiting H2S emissions.

One alternative was based

on operatingthe

lagoons without oxygen

and nutrient deficiencies and thus

achieving greater

BOD removal rates.

This alternative was based on treatability

data.

The

second alternative was based on operating the lagoons under oxygen and

nutrient limitations,

which decreased

BOD

removal rates but minimized

upgrade requirements.

Extensive

full-scale

system data was used to develop

a

model

for

evaluating

system performance under altemative conditions.

The project is currently

in the

final design stage.

Hazardous Waste

Groundwater Remediation Process Design, FLTG, Incorporated,

Crosby, Texas

P?vjectManager and LeadEngineer.

Responsible for a groundwater

remediation project for a company formed by 80 principle

responsible

parties.

This Superfund site groundwater treatability investigation

considered how bestto

upgrade the

existing treatment

facility.

Air

stripping, peroxidation,

ozonation, ultrafiltration,

carbon

adsorption, resin

adsorption,

and anaerobic degradationseparately and in conjunction with

activated sludge treatment were considered.

Following a series of batch and

continuous

flow treatability tests, activated sludge treatment followed by

granular activated carbon treatmentwas selected as the most cost-effective

means of

achieving discharge targets.

In addition, a cost-effective sludge

treatment and disposal planwere developed.

Textiles

Toxicity Reduction Evaluation/Toxicity Identification

Evaluation,

Globe Manufacturing, Gastonia, North Carolina

Prefect

Manager, Lead Engineer,

andAutbor.

Managed a wastewater

pretreatment project where the

industrial

discharge was cited

as the source

ofthe POTW’s

effluent aquatictoxicity problem.

Treatability tests were

conducted which screened the

effects of the

following treatment processes

on effluent toxicity reduction:

air

stripping, cation exchange resin,

activated

silica, macroreticular

resin,

granular

activated carbon, and biohydrolysis.

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T.

Houston

Flippin, P.E.,

DEE

Results of these tests

and further

desktop evaluations indicated the

biotoxicant was ethylene diamine and that activated sludge treatment would

provide the most cost-effective treatment.

Continuous flow treatability

studies were used to develop the process design

for the selected process.

Submitted

design basis report for the pretreatment facility, reviewed final

design drawings and specifications, and provided

startupassistance.

The

pretreatment facility eliminated all acute

and chronic toxicity

associated

with

the wastestream discharge at its flow contribution to the POTW.

Elements

of this projectwere published in

Water Science Technology,

Volume 29, No. 9

(1994).

Food Processing

Waste Minimization, Quaker Oats, Newport, Tennessee

Project

Manager, LeadEngineer,

andAutbor.

Developed a waste minimization

plan for a Quaker Oats

facility.

On-site wastewater characterization studies

coupled withinterview of site personnelwere used to develop practical,

cost-effective waste minimization recommendations.

Implementation of

the plan resulted in significant reduction of product losses and sewer

pretreatment surcharges.

Combined Municipal/Industrial Wastewater Management

ISP Chemicals, Calvert City, Kentucky

Principa/Engineer/Site CSM:

Investigation of theimpact of eightwaste

streams on the

onsite activated sludge process.

Clariant

Corporation,

Elgin, South Carolina

Provided alternative treatment system analyses prior to the

construction of a

Greenfield wastewatertreatment

facility.

Cooperative and Cost Effective Wastewater Treatment,

Ryan

Foods

Company, Murray, Kentucky

Project

Manager

and

PrincipalEngineer.

Worked with City of Murrayand

industry to developa

“win-win”

strategy

for minimizing wastewater

treatment costs for

both

the City

and industry.

Early estimates by the

City’s

consultant

had indicated that the

POTW

would have to spend

approximately $10 million to accommodate the discharge wasteload on the

POTW with

Ryan Foods at maximum loading

(and without pretreatment).

Estimates indicated that Ryan Foods would have to spend $3

million to

meet the

limits

requested

by the Cityifpretreatment were to be installed.

A

review of pertinent information indicated the opportunity for significant

savings byboth parties.

Treatability

studies were conducted

and POTW

performance data were reviewed.

This

work indicated that a much less

costly approach could be taken.

A final design was developed for the

pretreatment facility and installed

at a cost of $1.6

million.

The

pretreatment facility reduced the wasteload

by approximately7O percent.

However, the remaining wasteload to the POTW exceeded the “rated

capacity” of the POTW.

A site-specific analysis was conducted

and

used to

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Houston Flippin,

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rerate the capacity of the

POTW.

A

major component of this

analysis

was

sludge stabilization and alternative disposal methods.

This

rerating allowed

the POTW

to gain an

additional 29 percent

in rated capacity for a cost of

$0.7

million. So, in the end, the City

of

Murray

and Ryan Foods both saved

more than

$1

million

each.

The City

also

received definition

ofalternative

sludge

disposalmethods and a description of the incremental upgrades

that

would be required in the future as the

“real ratedcapacity” of the POTW

was approached.

Municipal Wastewater Management

Change Management Program, Metro Water Services, Nashville,

Tennessee

Assistant

Task

Managerfor Operations Grv4.

Worked with client to identify

cost-saving

action items to reduce annual

O&M costs at

two

water

treatmentplants

and

three wastewater treatment plants.

The purpose in

these reductions was to render the plants’

operating

costs competitive with

that estimated by private contractors and thus “stave off privatization.”

Annual savings of greater

than

$1,000,000 were identified.

Currently

serving

as advisor to

teams

implementing savings

regarding

sludge

thickening

and

dewateringand

aeration.

In addition to

this

work, have

assisted client in process troubleshootingwhich has allowed client to avoid

effluent non-compliance.

0etrochemical and Synthetic

Safety Kleen Corporation, East Chicago, Indiana

Lead Engineer,

Project

Manager, andAuthor.

Responsible foron-site

wastewater treatment

facility (WWTF) process troubleshooting and

training

to facilitate

compliance with pretreatmentlimits

at this

facility, one

of the

largest oil re-refineries in the world.

Treatability studies and process design

were required for

WWTF

modifications to accommodate increased

production and more

stringent pretreatment limits.

Brown

and Caldwell provided sampling and analytical

procedures modified

for cyanide, ammonia,

and

orthophosphate analyses.

A more

comprehensive and site-specific procedurewas implemented to evaluate the

chemical conditioning requirements of the mixed liquor. “In situ” oxygen

transfer was determined to assess upgrade requirements.

Treatability studies were conducted. The effects of operating temperature

(30°Cto 60°~

and F/M ratio

(0.1 lb COD/lb MLVSS

day to 0.7 lb

COD/lb MLVSS

day) on activated sludge

settleability

and effluent

quality

were evaluated.

The effects of

steam

stripping,

as a pretreatment step, on

activated

sludge systemperformance were evaluated.

Metals precipitation

with

lime, alum and

caustic was studied as a pretreatment and post

treatment process.

High pH air stripping

and

breakpoint chlorination were

examined as

effluent NH3-N reduction technologies.

Effluent peroxidation

and ozonation were evaluated as

a means of providing effluent total

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T. Houston Flippin,

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phenolics reduction.

The use of a biological selector and chemical

conditioning

(e.g., coagulation and flocculation) were investigated as means

of improving sludge

settleability.

A process design to upgrade the existing WWTF was provided and included

a four stage, aerobic biological selector,

temperature and pH

control,

coagulation, flocculation, increased RAS

pumping capacity, breakpoint

chlorination and tertiary filtration.

Final design guidance

was provided on

selection of equipment forthe

biological selector and

tertiary

filtration.

Booth Oil Company, Buffalo, New York

Lead Engineer andAutbor.

Responsible for wastewatersampling program to

define

treatmentprocess limitations under increased future loading

conditions.

Treatability testing was

conducted to evaluate alternatives for

controlling total phenolics discharge. Both improvements

in oil/water

separation and hydrogenperoxide treatment were considered.

A report

presenting

alternatives for upgrading WWTF

operations and for

prioritizing capital improvements was presented.

Groundwater Remediation Process Design, FLTG, Incorporated,

Crosby, Texas

Project

Manager andLeadEngineer.

Responsible for a groundwater

remediation project for a companyformed

by 80 principle responsible

parties

(almost exclusively petrochemical industries and refineries). The

groundwater at

this

siteexhibited

an influent COD of approximately 600

mg/L and had free product present. A groundwater treatability investigation

was conducted to determinehow best

to upgrade the

existingtreatment

facility.

Air stripping, peroxidation, ozonation,

ultrafiltration, carbon

adsorption, resin adsorption, and anaerobic degradation separately

and

in

conjunction with activated sludge treatment were considered.

Following a

series of batch and continuous flow treatability tests, activated

sludge

treatment

followed

by granular activated carbon treatment was selected as

the most

cost-effective means of achieving discharge targets.

In addition, a

cost-effective sludge

treatment and disposalplan were developed.

Reilly

Industries, Lone Star, .Texas

LeadEngineer, ProjectManagerandAutbor.

Responsible for a two-tiered

project at

this coal

tar plant. Treatability studies were conducted and

process designs

were developed for alternative wastewater treatment facility

upgrades that would allow plant to meet more restrictivepretreatment

limits. A

work plan was developed

in cooperation with TNRCC that would

allow

the POTWto seek permit reliefwhich in turn would

allow the plant

to not require

WWTF

upgrades.

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Permitting

Hunt Foods (formerly Quaker Oats), Newport, Tennessee

Project Manager

and

Principa/Engineer

on project involving wasteload

minimization, pretreatment facility design and negotiation of pretreatment

limits.

Laidlaw (formerly Osco, lnc), Nashville, Tennessee

Project Manager andPrincipalEngineer

on project involving pretreatment

facility

design, startup, troubleshooting, and pretreatment permit negotiations.

J. Hungerford Smith, Humboldt, Tennessee

PrincipalEngineeron

project involving pretreatment facility

design, POTW

upgrade

design, and pretreatment permit negotiations.

Ryan Foods Company, Murray,

Kentucky

ProjectManager

and

PtincipalEngineer

on project involving pretreatment

facility design, construction management, startup, operator training, POTW

upgrades, pretreatment permit negotiations, and negotiation ofre-rated

capacity of POTWwith Kentucky Division ofWater.

BF Goodrich Performance Materials,

Henry,

Illinois

Project Managerand PrincipalEngineer

on projectinvolving treatment

facility

design,

startup,

operator training, treatment facility troubleshooting and

NPDES permit negotiations withIllinois EPA. Meeting withIllinois Water

Pollution Control Board is pending.

ISP Chemicals, Texas City, Texas

ProjectManager and PrincipalEngineer

on project

involving modifying existing

NPDES permits

for stormwater

and

wastewater. Project also involved

conduct of testingto get adjusted metals limits.

OxyVinyls (formerly Geon Canada), Niagara Falls, Ontario,

Canada

ProjectManager and PrincipalEngineer

on projectinvolving treatment

facility

troubleshooting, operator training, and “NPDES equivalent” permit

negotiations.

Confidential Client, Barceloneta, Puerto Rico

Project Managerand Principa/Engineer

on project involving treatability testing

and pretreatment permit negotiations.

Toxicity Reduction

Thiokol Corporation, Brigham City, Utah

LeadEngineer

on effluent toxicity identification evaluation

(TIE)

followed by

toxicity reduction evaluation (TRE) as

a part of treatability studies fora

newly designed

WWTF.

The new WWTF replaced two existing

WWTFs

that were abandoned.

Acidification, air stripping, alkalinization, chemical

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Flippin, P.E., DEE

reductionwith sodium thiosulfate, filtration, granular activated carbon, ion

exchange (anion and cation), macroreticular resin, and metal complexing

with EDTA, were evaluated as a

means of achieving effluent toxicity

reduction for a selected wastestream.

High salinity was identified as the

toxicant.

The client decided to blend the

selected wastestream with other

wastestreams causing a decrease in wastewater salinity and an increase in

wastewaterBOD.

Activated sludge treatment followed by ozonation

as

a

means of toxicity reduction and disinfection was determined toprovide

consistent compliance

with

effluent BOD and toxicity limits.

A process

design was provided.

The newly designed WWTFs included gritremoval,

equalization, activated

sludge treatment, granular media filtration and

ozonation.

The final

design for the WWTF was reviewed for consistency

with the process design.

Confidential Client, Indiana

LeadEngineer and Project EngineerA

Toxicity Identification

Evaluation

(TIE)

was

conducted for a large-volume producer

of metal ingots and sheet

aluminum.

The TIE used Phase I laboratory characterization procedures,

single

stream toxicity testing, and resynthesis testing with major

wastestreams treated for

toxicity

removal.

Both

Ceriodapbnia

and the fathead

minnow were used in acute tests

throughout the study.

Study results

indicated that adsorptive organic compounds

associated with an internal

waste treatmentprocess were primarily

responsible

for

toxicity.

Pure

chemical

testswith

the

wastewater treatmentpolymer used at

the

site

indicated that the

polymer

may play a role in effluent toxicity.

A Toxicity Reduction Evaluation

(TRE) work plan was

also conducted for

the client to developa means to cost-effectively reduce

effluent

toxicity as

required by the

State.

Services includedwasteload characterization and

wastewater treatment

facility (WWTF)

optimization.

Memberships

National Society of Professional Engineers (NSPE)

Technical Associationof the Pulp and Paper Industry (TAPPI)

Water Quality Committee Member

Water Environment Federation

Pretreatment Committee Member

Chi Epsilon

-

National Civil Engineering Honor Society

Publications/Presentations

~Enhanced

Activated Sludge Treatment of High Strength Bio-inhibitory Industrial Wastewater’ with

R.

Rhoades,

10th

Annual WEF

Industrial Wastes Technical and Regulatoiy Conference,

Philadelphia, Pennsylvania, August 2004.

‘Treatment Alternatives for Removing Ammonia-Nitrogen from Landfill Leachate’ with RE. Ash and

B.N. Card, Annual Tennessee Solid and Hazardous Waste Conference, Gatiinburg,

Tennessee,

April2004.

‘Alternative

Considerations inSizing Aeration Basins

with W. W.

Eckenfelder, Design,

Performance and Operation of Biological Treatment Processes Pre-Conference Workshop,

VanderbiltUniversity and USEPA Conference, ‘Industrial Wastewater and Best Available

Treatment Technologies: Performance, Reliability, and Economics”,

Nashville, Tennessee,

February

2003.

P~\PROJ\23417

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Noveon~)-~enry

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OO2~FJippin_Houston

8

resune.doc

---

T. Houston Flippin, RE., DEE

‘Modifying Equalization to Provide Pretreatment of High Strength Wastewaters” with D.A. Moye,

19th Annual

North Carolina AWWMNEF Conference Proceedings,

Winston-Salem, North

Carolina,

November 2002.

‘Benefits of Using Nitrate as Nutrient in Activated Sludge Treatment Systems’ with W.

W.

Eckenfelder and D,A. Moye,

8th Annual WEF

Industrial Wastes Technical and Regulatory

Conference, Atlantic City, New Jersey, August2002.

‘Biological Treatment of High TDS Wastewaters,” with W. W. Eckenfelder and V. J. Boero, Water

Environment Federation-Industrial Waste Technical and Regulatory Conference, Charleston,

South

Carolina,

August 2001.

‘Competitive Performance for Water and WastewaterUtilities,’ with J.L

Pintenich, Nashville Quality

Forum, Nashville,

Tennessee, October 1999.

‘Reclaiming P01W Capacity,’ with M.L.

Roeder, American Society of Civil Engineers-Tennessee

Sectlon Annual

Meeting, Nashville,

Tennessee,

October1999.

‘Batch Activated Sludge Testing to Determine The Impact ofIndustrial Discharges-orrPOTW

Performance’, with J.S. Allen,

Proceedings of

1998 WEFIndustrial Wastes Specially

Conference,

Nashville, Tennessee,

March 1998.

‘Economics of Treating Poorly Degradable Wastewaters in the Chemical Industry,” with

KD. Torrens,

Proceedings of1998 WEF Industrial Wastes

Specialty

Conference,

Nashville,

Tennessee, March 1998.

‘Effects of Elevated Temperature

on the Activated Sludge Process,’ with W.W. Eckenfelder, Jr.,

Proceedingsof 1994 TAPPI lntemationalEnvironmental Conference,

Portland, Oregon,

April

1994.

‘Toxicity

Identification and Reduction in the Primary Metals Industry,’ presented at

Spring AIChE

Conference,

Atlanta, Georgia, April

1994.

“Treatability

Studies and Process Design for Toxicity Reduction for a Synthetic Fiber Plant,~with

J.L.

Musterman,

WaterScience Technology,

Vol. 29, No. 9(1994).

“Granular Carbon Adsorption of Toxics,’ technical reviewof chapter four in

Toxicity Reduction in

Industrial Effluents,

P. W. Lankford and W. W. Eckenfelder,

Jr.

(Eds), Van Nostrand Reinhold,

1992.

“Diagnosing and Solving a Pulp

and Paper Mill’s Poor Activated Sludge Settleability Problems

Through Treatability Studies,’with M. A. Bellanca,

Proceedings

of

1992 TAPPI Environmental

Conference,

Richmond, Vii~inia,1992.

‘Hydrogen Peroxide Pretreatment of Inhibitory Wastestream

—

Bench Scale Treatability Testing to

Full Scale Implementation:

A Case History,’ with R.

L. Linneman,

Proceedings ofChemical

Oxidation:

Technologyfor 1990’s,

Vanderbift University, Nashville,

Tennessee,

1991.

‘Control of Sludge Bulking in a Carbohydrate Wastewater Using a Biosorption

Contactor,”

with

W. W.

Eckenfelder, Jr.

and M. A. Goronszy,

Proceedings ofthe 39th Annual Purdue Industrial

Waste

Conference,

1984.

Research Topics

Biodegradation of PCB5 and HCB, research conducted at ECKENFELDER

INC.

Volatile Organic Compound Emissions from Activated

Sludge Systems,

research conducted at

ECKENFELDER INC.

Performance of Selective Bacteria in Industrial Activated

Sludge Systems,

research conducted at

Vanderbilt University

Biosorption for Improved Reactor Capacity, research conducted at Vanderbiit Univers+ty

Control ofActivated Sludge Bulking Through the Use of a Biosorption Contactor,

research

conducted at Vanderbilt University

Workshops

Instructor, Tennessee State University,

“Monitoring

Requirements, Operating Guidelines,

Calculations, and Troubleshooting,’ presented during ‘Aerobic Biological Wastewater Treatment

Workshop,’

Nashville,

Tennessee,

November1997, April 1998,

November1998,

and April

1999.

N

Instructor, Mississippi Water Pollution Control Operators’ Association, Inc., ‘Clarifier Operation and

Maintenance Workshop,’ Tunica, Mississippi, April

1997.

P\PROJ03417

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Noveon~Henry

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9

resumo.d~

---

T.

Houston

Flippin, P.E.,

DEE

Instructor, Brown and Caldwell, ‘Activated Sludge Wastewater Treatment Workshop, ‘attended

by

participantsfrom over

3 municipalities

and 10 industries, Nashville, Tennessee,

November 1999,

March 2000,

May 2001,

November

2002,

and November

2003.

Instructor, Tulane University and Louisiana Chemical Association, ‘Wastewater Strategies for

Industrial Compliance: Gulf Coast Issues and Solutions’, New Orleans,

Louisiana, December 2003.

Honors

Who’s Who of Citation’s Environmental Registry, 1991

Eckenfelder Inc. Technical Employee ofthe Year Award,

1990

Outstanding Young Men of America,

1986

P~ROJ\23417

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Noveon~-lenry

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10

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doe

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m

:5-

—÷

oJ

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EXHIBIT B

PERTINENT ARTICLES FROMLITERATURE

REVIEW

---

r

NATIONAL

CORN

L~

HANDBOOK

~

CROP FERTILIZATION

Nitrification Inhibitors for Corn Production

D.

W.

Nelson, University ofNebraska

D. Huber, Purdue University

Reviewers

K. D.

Frank, Univesrity ofNebraska

G. W.

Randall, University of Minnesota

R.

G. Hoeft,

Universityofillinois

W. I. Segars, University of Georgia

D. R. Keeney, University of Wisconsin

J.

T~Touchton, Auburn University

G.

L. Malzer,

Universityof Minnesota

L. F

Welch, University ofIllinois (retired)

H. F Reetz, Jr., Potash & Phosphorus Institute, Illinois

Nitrogen (N) is an essential element for plant

growth and reproduction. The amounts of N taken

up

by corn

exceed

those of any other soil-derived

element. Today an average

25

of plant-available N

in soils

(ammonium and nitrate) originates from the

decomposition (mineralization) of organic

N

compounds in humus, plant and animal residues, and

organic fertilizers, 5

from

N in rainfall, and 70

from

applied inorganic

N fertilizers

(Figure 1). In soils,

organic N

is converted to ammonium through

microbial

decomposition. Ammonium formed in soil,

added as fertilizer, or in precipitation is rapidly

oxidized to nitrate in the nitrification process carried

out by specific bacteria.

Nitrification results in the

production of nitrate, a

form of plant-available N which

is readily lost from soils. Nitrification inhibitors are

chemicals that slow down ordelay the nitriflcation

process, thereby decreasing the possibility that large

losses of nitratewill occur before the fertilizer nitrogen

is taken

up by plants. This publication discusses

N

losses from soils, characteristics of nitrification

inhibitors, and how nitrification inhibitors can

be used

to improve efficiency of corn

production.

THE NITRIFICATION PROCESS

Ammonium (NH4) added to soils or formed

by

decomposition of organic N compounds is oxidized to

nitrite (NO2)

by

Nitrosomonas

bacteria, and nitrite is

further oxidized to nitrate

(NO3) by

Nitrobacter

bacteria in

a process termed nitrification (Figure 1).

Nitrate is normally the form of N taken up by plants;

however, most plants can also assimilate amrrionium.

In

most soils, nitrification of applied ammonium is

rapid

(2-3 weeks), but nitrification rates are greatly

IOWA

STATE

UNIVERSITY

University Extension

NCI-I-55

reduced by cool soil temperature (50°F),low pH

(5.5),

and waterlogged conditions. Nitrification converts

ammonium,

a

positively charged ion that is bound to

clay and organic

matter, to nitrite and nitrate,

negatively charged ions

that arefree in the soil

solution and

are readily lost from the plant rooting

zone of soils.

N

LOSS FROM SOILS

Only about 50

of the applied

N is taken up by

corn

during the year following fertilizer addition. About

25

is immobilized during residue

decomposition or

remains

in the soil as nitrate. The remaining 25

is

lost from the plant rooting zone by leaching and/or

dentrification.

(See Table I for a generalized estimate

of the fate of fertilizer N added to soils.) Some of the

immobilized

N will be

mineralized (5

peryear) and

will be available to subsequent crops. Nitrate

remaining

In the profile at the end of the cropping

season will be

available to the succeeding crop unless

lost over the winter and spring by leaching or

dentrification.

Leaching is important in coarse-textured soils.

Nitrate may be leached from

naturally well-drained or

tile-drained soils

by percolating water. One inch of

infiltrating water will

move nitrate

I

to 2.5

inches

downward in clay loam and sandy soils, respectively.

Thus, during periods of excess

rainfall, leaching may

move nitrate out of the effective rooting zone of

plants.

Denitrification (the microbiological conversion

of

nitrate and nitriteto gaseous forms of N) is the major

pathway of N loss from most fine-textured soils.

It

normally

occurs in

soils

that become

waterlogged by

NCH 55

Revised

February 1992

Electronic version July

20C1

---

Figure

1. The nitrogen cycle in soils (adapted from Nitrogen in Agricultural Soils).

excessive rainfall or irrigation.

Denitrification occurs at

maximum rates when soils

arewarm (60°F),pH

values

are high (7),

nitrate isplentiful, and an energy source

(carbon) is available.

In waterlogged soils,

more than

100

lb. of nitrate N per acre can

be denitrified within a

5-day period. However,

in cold

soils (40°F)or soils

with low pH values (5), denitrification rates are slow.

TYPES AND USES OF

NITRIFICATION INHIBITORS

Nitrification

inhibitors

(NI)

are chemicals that

reduce the rate

at which ammonium is converted to

nitrate by killing or interfering with the metabolism of

Nitrosomonas

bacteria

(Figure 1). The loss of N from

the rooting zone can

be minimized by maintaining

applied

N in the ammonium form during periods of

excess rainfall

prior to

rapid N uptake by crops. A

numberof compounds have been shown to

inhibit

nitrification in laboratory and field

studies (Table 2);

however, only N-Serve® and Dwell® have U.S.

Environmental

Protection Agency approval foruse

on

cropland in the United States. Additional compounds

are used in Japan and other countries; and

registration isexpected for additional compounds in

the U.S.

N-Serve iscurrently

labeled forcorn, sorghum,

wheat,

cotton,

rice, and

other crops and is sold

in

emulsifiable

and nonemulsifiable formulations. Dwell

was registered as

a nitrification inhibitor

in 1982,

but it

is uncertain

if the product will be

marketed. Both

chemicals are effectivenitrification inhibitors when

Table 1. GeneralIzed

Fate

Applied

to Corn.1

of Fertilizer Nitrogen

Soil texture

Fate of applied

N

coarse

medium

and fine

Plant uptake (first year)

-—

of applied N—---

40-60

50

-

60

Remains In soil as organic

20 -25

25- 30

and

inorganic N

Lost from root zone:

Denitrificatlon

5

-

10

15 -25

Leaching

15-20

0-10

I

Average values over years for soils

in the Combelt and

southeastern

U.S. and irrigated soils of the Great Plains and

western valleys.

0.5 lb. of active ingredient (a.i.)

peracre is used in

a

band application with anhydrous ammonia or N

solution fertilizers.

N-Serve and Dwellmay also

be impregnated on

solid fertilizers or mixed with

N solution fertilizers prior

to broadcast applications.

However, incorporation of

the nitrification inhibitor-treated fertilizer must occur

shortly after application because

both compounds are

volatile.

Higher rates

(2

to

4 times

band applications)

of N-Serve and Dwell are often required to control

nitrification of broadcastammoniacal fertilizers.

Recent studies have shown that NI

can

also be

effectively used with liquid animal

manures and

sewage

sludges

that are injected

into

the soil.

ATMOSPHERIC

GASES

N2, NO2,

N20,

NO

A

A

A

ri

I

NITROGEN

I

FERTILIZER

I

I

/

/

/

#5

—

V

LEACHINGTO

GROUNDWATER

OR TILE DRAINS

2

---

Table 2. Compounds Marketed or Proposed as

Nitrification

Inhibitors.

Common or

Registered in

Chemical name

trade name

Manufacturer

the U.S.A.

—

EFFECTS OF NITRIFICATION INHIBITORS

A number of studies throughout the

United States

have demonstrated that NI

effectively retards the

conversion of ammonlum

to nitrate

in a variety of

soils.

Results indicate that application of NI

delays the

conversion of ammonium to

nitrate for 4 to

10 weeks,

depending upon soil

pH

and temperature. With fall

applications of N fertilizers, NI

minimize nitrification

until low soil temperatures (40°F)stop the process.

With

spring applications,

NI prevent the formation of

nitrate during the late spring when rainfall is high and

uptake of N by crops Is low.

Corn yields are often increased

as

N losses from

soils are reduced by the application of NI

with both

conventional tillage and reduced tillage systems

(Table 3). The potential benefit from

NI application

depends

on a

number of site-specific factors, such as

soil type, climate, cultural practices,

and N

management program. Highest probability of yield

response from NI

occurs with excessively drained or

poorlydrained soils because

of N losses from

leaching and denitrification, respectively. For example,

a study in Indiana with faIl-applied anhydrous

ammonia showedthat

N-Serve application increased

corn yields by 300

with

a very poorly drained silty

clay soil and

1

with

a well-drained sandy loam soil.

Significant corn yield responses from NI additioti have

also been observed with irrigated sandy soils

(Table

4). Yield responses from

NI

are more frequent

with fall

N applications than with spring applications

because of lower N losses from denitrificatlon

normally experienced when fertilizers

are applied

nearer to

the timeof crop

need. There have been

consistent yield responses from NI added to

ammoniacal fertilizers forcorn produced with a

no-till

system, presumably because of larger N losses from

denitrification normally experienced with this

production

method.

The Increased availability of inorganic N and the

presence of ammonium in the soil resulting from NI

addition also

have been shown to increase the protein

concentration of corn grain

(Table 5). The feeding

value of corn increases as the protein level increases.

The application of NI to inorganic and organic N

fertilizers also

has reduced the severity of

Diplodia

and

Gibberella

stalk rots of corn,

likely because of

altered

N metabolism in plants assimilating the

ammonium form of N (Table 6). Cornstalks in areas

receiving NI-treated fertilizers tend

to remain green

later in the growing season and havethicker rinds,

both of which

reduce pathogen effects

and

lodging.

Grain moisture

content at harvest is unaffected by NI

addition to fertilizers.

The amounts

of nitrate leached Into groundwater

and ozone-destroying nitrous oxide

(N20)

emitted into

the atmosphere through denitrification are reduced

by

NI

application. The

use of NI

also gives greatflexibility

in timing the application of N fertilizers. For example,

with most Cornbelt soils

all of the

N

needed for a corn

crop can

be applied

as anhydrous ammonia during

Produced

commercially:

2-chloro.6-(t,ichloromethyl)-pyridlne

5-ethoxy-3-trichloromethyl-1, 2. 4-thiadiazol

Dicyandiamide

2-amino-4-chloro-6-methyl-pyrimidine

2-mercapto-benzothiazole

2-sulfanilamidothiazole

Thiourea

Dow Chemical Co.

Uniroyal Chemical

N-Serve

Dwell, Terrazole

(etradiazol)

DCD

AM

MBT

ST

lU

Yes

Yes

SKW Trostberg AG

Mitsui Toatsu

Co.

Onodo Chemical

Industries

Mitsui Toatsu Co.

Nitto Ryuso

No

No

No

No

No

Proposed as nitriflcation

inhibitors:

2,4-diamino-6-trichloromethyl-5-triazine

Polyetherionophores

4-amino-I, 2, 4-trlazole

3-rnercapto-1, 2, 4-triazole

Potassium azide

Carbon bisulfide

Sodium trithiocarbonate

Ammonlum dithiocarbamate

2, 3, dihydro-2, 2-dlmethyt-7-benzofuranol

methyl-carbamate

N-(2, 6-dimethylphenyl)-N-(Methoxyacetyl)-

alanine

methyl ester

Ammonium thiosulfate

1-hydroxypyrazole

2-methylpyrazole-1 -carboxamide

Amer. Cyanamid Co.

Amer. Cyanamid

Co.

Ishihara

Industries

Nippon Gas

Indus.

Plttsb. Plate Glass Co.

Imperial Chem.

Indus.

Imperial Chem.

Indus.

FMC

FMC

Furadan

(carbofuran)

No

No

No

No

No

No

No

No

No

No

Olin Corp.

CMP

BASF

GOR

No

No

No

3

---

the previous fall if a NI is

used, thereby reducing the

workload in the critical

spring

planting season. The

use of NI

permits early spring application of N

in many

areas of the United States where N losses are

a

consistent problem.

Data in Table

3 show that

NI addition does not

result in yield increases in

all soils and climatic

conditions.

In

fact, in some situations there is a low

probability of a

corn yield increase from NI.

Since the

purpose of NI

application is

to

increase the

efficiency

and amount of N available to plants by reducing N

losses, no response to NI

will be obtained

during

seasons

orwith soil types having little orno

N

loss.

Little orno

N loss occurs during seasons with below

average rainfall following

N

application because

N

loss through leaching and denitrificatlon is directly

related to the amount and distribution of rainfall and

the drainage characteristics of the soil.

No yield response will be obtained from NI

addition when

N

rates

used are far in excess of those

required for maximum

yield. For example, if maximum

corn

yields could be obtained with 150 pounds of N

per acre but 300 pounds per acre are applied,

as

much as one-half of the applied

N could be

lost before

a decrease in yield occurs. Late side-dress

injections

of N may reduce yield through mechanical damage to

the root system and increased root rot.

Immobilization

of late-season applied

N with a

NI may further

exacerbate this condition.

In sandy soils with very low cation exchange

capacities,

the addition of NI to ammoniacalfertilizers

may not reduce N

loss or increase crop yield because

of differential movement of ammonia and NI from

the

zone of placement. Some

studies have shown that

ammonium ions were leached below the NI treated

zone by rainfall and irrigation

water. In this situation,

nitrification deeper in the profile

produced nitrate that

was subsequently removedfrom the rooting zone by

leaching.

N rate

Nitrlflcatlon InhibItor

None

N-Serve

Dwell

lb/acre

---—-corn yield, bu/acre——-

0

59

—

—

60

89

119

98

120

105

151

145

180

136

170

171

240

171

182

186

N applied

Treatment

NH3

NH3

+

N Serve

Iblacre

—grain

protein,

—

0

6.76

—

60

7.76

9.24

120

9.38

10.60

180

10.80

11.71

I

Study conducted In Indiana using 373

x Mo 17

corn hybrid.

Table 6.

Effects of a Nitrification Inhibitor on Stalk Rot

of Corn.1

No. of

studies

N

source

Treatment

N

N

+

N Serve

—----

plants with stalk roV------

3

NH3

38

16

4

Swine manure

54

23

1

Average values for all locatIons, years, and

N rates from

studies In Indiana.

Table 5. Effect of a Nitrlflcation InhIbitor on Corn

Grain Protein Concentration.1

Table 3. Effects on Grain Yields of Corn Grown with

Conventional and No-Till Systems

cation Inhibitors to Fall- and SprIng-Applied Ammoniacal Fertilizers.’

frem-Addition-of-Nit-r-ifl~

~

Time

of

No. of

No. of yield

Yield Increase

LocatIon

applicatIon

experiments

increases from NI2

from NI3

Indiana

FaIl

24

17

12.5

Spring

51

29

5.8

Spring (no-till)

12

9

10.0

No. Illinois

FaIl

12

5

5.0

Spring

14

2

So.

Illinois

Fall (NH3)

7

7

Spring (NH3)

9

7

Spring (no-till)

2

2

-1.0

4.6

4.6

8.5

Fall (N solution)

5

4

Spring (N solution)

5

2

3.3

-12

Kentucky

Spring (no-till)

8

7

14.3

Wisconsin

Fall

2

1

4.7

Spring

2

0

1.5

‘Adapted from

R. 0. Hoeft 1984. Current status of nitrification

InhibItors.

In R. O~Hauck(ed.)

Nitrogen

in

Crop Production. Am.

Soc. of

Agronomy, Madison, WI,

2

Significant at 95

probabilIty level.

3

percent yield Increase across all

N rates and locations.

Table 4.

Effects of Nltrificatlon Inhibitors onthe YIeld

of Irrigated Corn Fertilized with

Urea. (Hubbard

Loamy Sand).1

Taken

from 0. L. Maizer,

T.

J. Graft, and

J.

Lensing.

1979.

Influence of nItrogen rate, timing of nitrogen applIcation and

use

of nitrificatlon

Inhibitors for Irrigated

spring wheat

and corn.

In

Univ. Mlnn.

Soil Series 105

Report

on

Field Research In Soils.

4

---

WHERE SHOULD

NITRIFICATION INHIBITORS BE USED?

The response ofcorn to applications of NI with

ammoniacal fertilizers varies greatly

throughout the

United States

because of major differences in

N loss

potential from differing

climate,

soils, and production

systems.A

summary of research results

on corn yield

responses from NI additionfor

various corn

production regions is

presented

in Table 7, and the

probabilities for obtaining a yield response from NI for

several combinations of region, soil texture, and time

of fertilizer application

are given

in Table 8. The

addition of NI to fertilizer should

be looked upon

as

Insurance against N loss, and, thus, a decision to

use

NI should be

based on

the probability of

obtaining

yield increases

over a

period oftime,

e.g., 5

years.

The usefulness of NI forcorn production in three

general regions of the United States is discussed

below.

Southeast

The response ofcorn to NI applications in the

southeastern United States has been

mixed. The

relatively high soil temperatures during the winter

result In nitrification of fall-applied N and subsequent

leaching or denitrification of the nitrate that is formed.

The

addition

of NI

does not alleviate this problem

becauseof the limited longevity of thecurrently

registered inhibitor compounds in soil

and the long

period of time between N application and crop

uptake

of the nutrient. Thus, yield responses to

NI added to

fall-applied fertilizers

have not been

consistently

observed. A number of studies have shown modest

corn yield increases from the addition of NI

to spring-

applied

N

even though inhibitor persistence is limited

by high soil

temperatures. Overall, the probability of

corn yield response from currently available

NI in the

southeastern U.S. is poor for fall-applied N

and fairto

poor for spring-applied N.

Eastern

Cornbelt

The

response of corn to

NI

application

has

been

more consistent over years in the eastern Cornbelt

than other portions of the United States

because of

high rainfall, finer textured soils, and cold

soil

temperatures during the winter.

However, overall only

about 50 and

70

of the trials with spring- and fall-

applied N have shownyield response from NI. Yield

responses have been obtained with both spring- and

fall-applied

N in Indiana, Kentucky, Ohio, and

southern Illinois. The consistency of yield responses

to

NI

has been less in Michigan, Wisconsin, Missouri,

central and

northern Illinois, and

Iowa than

in

other

eastern Cornbelt states.

However, all states

in the

eastern

Cornbelt have studies showing

corn yield

increases from NI addition, and the largest and most

consistent increases are normally observed with fall-

applied

N or with non-tillage programs.

There

is a good probability of obtaining a yield

increase from application of NI to fall-applied

ammoniacal fertilizers

in the eastern Cornbelt

because of the large N

loss normally associated with

fall applications. The use of NI will allow producers to

apply N

fertilizers somewhat earlier than generally

consideredfeasible (50°Fis traditionally considered

the maximum

soil temperature for application of

ammoniacal fertilizers

in the fall without a

NI).

Fall

application of N is not recommended for low CEC

coarse-textured soils because of the possibility of

ammonium leaching.

The probability is good that NI added to spring-

preplant N will Increase yields of corn growth on fine-

textured soils of the eastern Cornbelt because of the

likelihood of N losses by denitrification after

fertilization. Only a fair probability exists for a yield

response to

NI added with spring-preplant N applied

to

silt

barns and coarser textured soils. The

probability of loss in such

soils depends upon

the

nitrification rate following fertilization, the internal

drainage ofthe soil, and the

distribution

and

intensity

Region

Time of

application

of studies with

yield Increase

yield

increase2

Southeast (GA,

MD. NC, SC, TN)

Fall

Spring

17

43

14

15

Eastern Cornbelt (IL,

IN, OH, KY)

Fall

Spring

Spring (no-till)

69

51

82

9

3

13

Northem

Cornbelt (MI, MN, WI)

not irrigated

FaIl

Spring

25

17

5

12

Western Cornbelt (KS, MN, NE)

irrigated coarse-textured

soils

Spring

52

30

Western Cornbelt (KS,

NE)

irrigated medium- and

fine-textured soils

Spring

10

5

Table

7. RegIonal Summary of Corn Yield Responses from Nitrification

Inhibitors Addedto Ammonlacal

Fertilizers Appled

at Varying Times.1

‘Datataken from a variety of research progress reports and published materials.

2Average Increases obtained

in

experiments where NI addition gave significant yield increases.

5

---

of rainfall. Heavy

rains occurring 2 to

8 weeks

after

fertilization may result in extensive

N

losses and yield

responses to NI application.

However, if a below

average rainfall

period follows fertilization, little N loss

or response to

NI will occur.

Western Cornbelt

Few yield responses

to

NI have been

observed

with dryland corn orirrigated

corn produced

on fine-

textured soils

in Minnesota, North Dakota,

South

Dakota,

and other states west of the Missouri river.

However, the use of NI

has resulted in increased

yields in areas

where preplant N

is

applied to irrigated

corn grown on

sandy soils. Data from

Minnesota

(Table

4) illustrate the type of responses that are

sometimes obtained when a

NI

is used to reduce

nitrate leaching in irrigated sandy soils.

There is

poor probability of yield response with

spring-appliedfertilizer for dryland corn production in

the western Cornbelt; however, with irrigated coarse-

textured

soils the probability ofa yield increase

improves. There is a fair probability of a response to

NI with fall applied fertilizer on finer textured soils. Fall

application of arnmoniacal fertilizers

is not

recommended for sandy soils.

ADDITIONAL CONSIDERATIONS WHEN

USING NITRIFICATION INHIBITORS

More consistent yield responses have been

obtained with no-till grown corn than

with conventional

tillage

systems fertilized in the spring

(Tables

3 and 8).

This finding

results from greater infiltration rates,

higherwater contents, a higher population of

denitrifying bacteria in no-till soils and, thus, increased

N

losses from

leaching and/or denitrification.

The

probability of yield responses

to NI

added to

spring-sidedress-applied N

Is considered low for all

soils

because the fertilizer is added close to the time

of plant uptake. However, a few investigators

in

the

eastern Cornbelt have observed significant yield

increasesfrom

NI

added to

early sidedressed N

fertilizers.Additional studies are needed at several

locations in all corn-growing regions to determine the

long-term probability of a response to NI application

with sidedress N

should exist

on coarse-textured soils

receiving excess

rainfall

or irrigation

water.

The

commercially available NI

have properties

that affect how they can be

addedto various types of

fertilizers. N-Serve and Dwell can

be impregnated

on

solid fertilizers, or an

emulsifiable formulation may be

mixed with N

solution fertilizers.

N-Serve can be

added directly to bulk anhydrous ammonia because of

its high

solubility in liquid ammonia. However,

Dwell is

not soluble in ammonia, butcan

be added to

anhydrous ammonia with a small electric pump that

meters the compound

into the ammonia stream

between the nitrolatorand the manifold system

on

the

applicator.

Soil texture

Application

time

Region of the U.S.

Eastern

Southeast

Cornbeit

Western

Cornbelt

—Probability of corn yield

increase’-—

Sands

Fall

Spring

Poor

Poor

Fair

Fair

Poor

Fair2

Loamy sands, sandy

barns, and loams

Fall

Spring

Poor

Fair

Fair

Fair3

Poor

Fair3

Silt barns

Fall

Poor

Good

Fair

Spring

.

Fair

Fair3

Poor

Clay loams and

clays

Fall

Spring

Poor

Good

Fair

Good

Fair

Poor

Reference to products in

this publication is not intended

to be

an endorsementto

the excius onoiotherswr,icn

using such

products assume responsibility for their use in accordance with

may be

similar. Persons

A publication of the National Corn Handbook Project

and justice for all

The

U.S. Department

ofAgriculture (USDA) prohibits discrimination

In all its

programs and activities on

the

basis of

race, color,

national origin, gender,

religion, age,

disability, political

beliefs,

sexual orientation, and marital or

family status. (Not all prohibited

bases

apply

to all programs.) Many materials

can be made available in alternativeformats forADA

clients. To file

a

complaint ofdiscrimination, write USDA. Office of civil Rights, Room 326-W,

Whitten 8ullding,

14th and

IndependenceAvenue, SW,

Washington,

oc

20250-9410or call

202-720.5984.

Issued In

furtherance

of Cooperative

Extension

work, Acts of

May

8 and June

30,

1914,

in cooperation

with

the

U.S. Department ofAgriculture.

Stanley

R.

Johnson, director, cooperative Extension Service, Iowa State University of

Science and Technology, Ames. Iowa.

File:

Agronomy2-2

Table

8. Probability of Corn Yield Increase from the Addition of NI to Ammoniacal Fertilizers Applied

at

Varying Times.

‘Poor

=

less than 20

chance of yield Increase

at any locatIon any year; fair

=

20.60

chance ofincrease; good

=

greater than 60

chance ofIncrease.

2

Fair for Irrigated soils, poor for dryland corn.

Good

for no-till production systems.

---

m

C-)

---

EXHIBIT C

SUMMARY

DOCUMENT OF EFFLUENT AMMONIA-NITROGEN

REDUCTION EVALUATIONS FOR NOVEON-HENRY

PLANT

---

BR OWN

AND

CALD

WELL

MEMORANDUM

TO:

Mark Latham, Esq.

JOB NO:

27-21522.001

FROM:

T. Houston Flippin, P.E., DEE

DATE:

May 17, 2002

SUBJECT:

Ammonia-Nitrogen Treatment Alternatiyes

Support Exhibit

Brown

and

Caidwell

is

providing

below

a

summary

of

information

intended

to

support

the

discussion

of

ammonia-nitrogen

(NH3-N)

treatment

alternatives

described

in

the

Petition

For

Adjusted

Standard.

This

information is

the

product of treatability testing,

full-scale plant

testing,

and data provided by the

Noveon-Henry Plant staff.

In

order to develop treatment alternatives, a “design influent and effluent wasteload” was

required.

This

wasteloads were

developed based on individual wastestream data gathered in

1995 and effluent

data gathered in 1999 through

2000

and are

summarized

below in Tables I and 2.

A flow schematic

is provided in

Attachment A of the wastewater treatment

facility

(WWTF)

provided

at the

Henry

Plant.

Table

1.

InfluentWasteload Used In Developing Treatment Alternatives

Parameter

PVC Tank

PC Tank

C-18 Tank

Holding Pond!

Well No.3 Waters

Total

Flowrate, gpm

Average

401

107

6

46

560

Peak

499

150

15

105

769

SCOD, lbs/day

Average

2,650

8,280

1,320

50

12,300

Peak

4,330

10,840

2,940

50

18,160

Estimated BOD, lbs/day

Average

795

.

2,485

395

15

3,690

Peak

1,300

3,250

880

15

5,445

TKN,

lbs/day

Average

459

494

82

3

1038

Peak

640

693

198

7

1537

NH3-N, lbs/day

Average

295

62

27

1

385

Peak

411

87

66

3

571

P:\PROJ\21522\M051702

Latham.doc

---

Memorandum

to

MarkLatham, Esq.

May

17, 2002

Page 2

Table 2.

Effluent Wasteload Used In Developing Treatment Alternatives

Parameter

Effluent Value

NH3-N, lbs/day

Average

909

Peak

1408

The following treatment alternatives

were considered for ammonia reduction.

Illustrations of each

are

provided in Attachment A.

•

alkaline

air stripping of PC Tank contents with off-gas

collection and treatment (No.

I)

•

alkaline

air stripping of PVC Tank

contents

(No.

2)

•

alkaline

air stripping of secondary clarifier effluent (No. 3)

•

struvite

(NH4MgPO46FI2O) precipitation from combined influent (No.

4)

•

breakpoint chlorination of secondary clarifier effluent (No. 5)

•

nitrification of PVC Tank wastewater (non-PC wastewaters) (No. 6)

•

nitrification of combined wastewater (No. 7)

•

ion exchange treatment of final

effluent

(No. 8)

•

ozonation of

final effluent

(No.9)

•

nitrification of secondary clarifier effluent (tertiary nitrification)

(No. 10)

A

summary

of

conceptual

level

capital

costs

for

each

of

these

alternatives

are

summarized

in

Table 3.

The total costs presented in

this

table are considered accurate to within ±

30 percent.

Table

3.

Capital Cost Estimates For Treatment Alternatives

Upgrade Components

Upgrade Costs in

$

Millions for Treatment Alternative Number

1

2

3

4

5

6

7

8

9

10

Pretreatment

0.65

0.10

0.00

0.05

0.00

0.02

0.43

0.00

0.00

0.00

Primary Treatment

0.00

0.00

0.00

0.00

0.00

0.25

0.00

0.00

0.00

0.00

Secondary Treatment

0.00

0.00

0.00

0.00

0.00

1.12

1.91

0.00

0.00

0.00

Tertiary Treatment

4.21

0.75

0.57

4.6

4.00

Sub-total

0.65

0.10

4.21

0.05

0.75

1.39

2.34

0.57

4.6

4.00

Sitework/Interface Piping

0.10

0.01

0.32

0.01

0.11

0.21

0.35

0.09

0.20

0.50

Electrical/Instrumentation

0.25

0.16

0.40

0.16

0.26

0.36

0.50

0.24

0.50

0.30

Contractor Indirects (8

)

0.05

0.01

0.34

0.00

0.06

0.11

0.19

0.05

0.37

0.32

Engin./Constr. Mgmt (18 )

0.12

0.02

0.76

0.01

0.14

0.25

0.42

0.10

0.83

0.72

Performance Bonds (I

)

0.01

0.00

0.04

0.00

0.01

0.01

0.02

0.00

0.05

0.04

Sub-total

1.17

0.30

6.07

0.22

1.33

2.33

3.82

1.04

6.54

5.88

Contingency

(15 )

0.18

0.04

0.91

0.03

0.20

0.35

0.57

0.16

0.98

0.88

Total Installed Cost

1.35

0.34

6.98

0.25

1.53

2.68

4.40

1.20

7.52

6.76

l’:’PROJ\21522\M051702

Latham.doc

---

Memorandum to Mark Latham, Esq.

May

17, 2002

Page

3

A summary of conceptual level operations and maintenance costs for each of these alternatives are

summarized in

Table

4.

The

total costs presented

in

this

table

are considered

accurate

to

within

±

30 percent.

Table

4.

Annual Operating and

Maintenance Cost Estimates For Treatment Alternatives

Cost Components

Annual O/M Costs in

$ Thousands for

Treatment Alternative Number

1

2

3

4

5

6

7

8

9

10

Labor ($40/hour)

32

32

60

8

.

60

60

60

60

30

60

Electrical ($0.06/kwh)

64

29

214

0

4

10

98

10

1,363

88

Natural

Gas ($0.06/therm)

18

0

0

0

0

0

0

0

0

0

Chemicals (Plant Costs)

0

1,794

575

642

1,028

218

788

147

226

459

ResinReplace. ($35/cu ft)

0

0

0

0

0

0

0

242

0

0

Off-site Disposala

0

0

0

0

0

0

0

51

0

0

MaintenanceMaterials~’

17

2

105

1

19

11

45

14

115

22

Sub-total

130

1,858

954

652

1,111

299

990

524

1,735

629

Contingency

(10

)

13

186

95

65

111

30

99

.52

173

63

Total Annual

143

2,044

1,049

717

1,222

329

1,089

576

1,908’

692

a Cost of disposing of spent

regenerant containing

29.7

assumed to be $0.10/gallon.

b

Based on 5 percent of equipment costs.

percent

by

weight NH4C1

(8

percent N)

A

comparison

of alternatives

regarding present worth

costs and ammonia

removal is provided in

Table 5.

Table 5.

Comparison of Present Worth Costs and Ammonia Removal for Treatment Alternatives

.

Components

Treatment Alternative Number

1

2

3

4

5

6

7

8

9

10

NH3-NRemoval,lbs/day

247

147

864

217

891

423

891

891

891

891

NH3-N Removal,

27

16

95

24

98

47

98

98

98

98

Present Worth Costs

•

Capital

1.35

0.34

6.98

0.25

1.53

2.68

4.40

1.20

7.52

6.76

•

0/Ma

0.96

13.71

7.04

4.81

8.20.

2.20

7.31

3.87

12.80

4.64

•

Total

2.31

14.06

14.02

5.06

9.73

4.88

11.71

5.07

20.32

11.41

a

Based on 10 year period,

8 percent annual interest,

and no

salvage value.

P:\PROJ\2l522\M05t702 Latham.doc

---

BROWN

AND

CALD

WELL

Nashville, Tennessee

P:/PROJ/21522/~ig1

FIGURE

BLOCK FLOW

DIAGRAM

OF WASTESTREAM

SOURCES AND

WWTF

---

~

________

_____p~j~ren~j

~~u’.-Pc

Wastestreaj~—

~

PC

Tank

To Primary

Treatment

ALTERNATIVE NO.1

- ALKALINE AIR STRIPPING OF PC TANK CONTENTS

~~icSod*

2~’~

Defoamer

__—~~

Air

~furi~±~

PVC

Tank

To Primary

Treatment

ALTERNATIVE NO.2- ALKALINE AIR STRIPPING

OF PVC TANK CONTENTS

Off-Gas

~

Treatment

_____

Packed Tower

I

~

SulfuricA ~

ALTERNATIVE NO.3- ALKALINE AIR STRIPPING OF SECONDARY CLARIFIER EFFLUENT

I—

I

Existing Equipment

EJ

New

Equipment

BLOCK FLOW

DIAGRAM

OF ALKALINE

AIR STRIPPING

TREATMENT ALTERNATIVES

(Nos.

1, 2, and 3)

BROWN

AND

I

C

A

L

D

w

E

L

L

Nashville,

Tennessee

PJPROJ/21522/Fig

---

—

-It-

---

r

~-~---

-‘;

~

pH Adjustment

Coagulation

Sedimentation

To_Biotreater~

I

To FilterPj~’~

__

-‘

~icSod~-

NOTE:

Existing

FeCI3 Addition would be discontinued

-

Existing Equipment

E~J

New

Equipment

BLOCK FLOW

DIAGRAM

OF STRUVITE

-

(No.4)

BROWN

AND

(~

A

~

m

i~

i

i

Nashville,

Tennessee

PJPROJ/21522/F1g3

i-’

1/

YT

Li

Li

Li

---

Existing

Equipment

~

New

Equipment

BLOCK FLOW

DIAGRAM

OF BREAKPOINT

CHLORINATION

ALTERNATIVE

-

(No.5)

BROWN

AND

PJPROJ/215221F194

C

A

L

D

W

E

L

L

Nashville,

Tennessee

---

_____________

—

——

.

I

—

__________

~I

11.11

.

I

II.•.

~

Existing Equipment

New

Equipment

BLOCK FLOW

DIAGRAM OF NON-PC WASTESTREAM

NITRIFICATION TREATMENT ALTERNATIVE

ROWN

AND

(No.

6)

P:/PROJ/21522/Fig

ALD

WELL

---

~iI

-

--

-

----

I

~-

-

Existing Equipment

L.....J

New

Equipment

l\\\\\\’~ Upgraded Equipment

BLOCK FLOW

DIAGRAM OF COMBINED WASTESTREAM

(No. 7)

BROWN

AND

PJPROJ!215221Fig 6

CALD

WELL

---

Treatment

L—.~linoisRiver

V

-

I

I

Existing

Equipment

LT~1

New

Equipment

FIGURE 8

-

BLOCK FLOW

DIAGRAM

OF OZONE

TREATMENT ALTERNATIVE

-

(No.9)

-

BROWN

AND

C

A

L

D

~

B

L

L

Nashville,

Tennessee

P:/PROJ/21522iFig

8

-

________________

---

I

Existing

Equipment

£~J

New

Equipment

BLOCK FLOW

DIAGRAM

OF TERTIARY

(No. 10)

BROWN

AND

CALD

WELL

Nashville, Tennessee

P:/PROJ/21522JFig 9

---

m

:3-

C

---

EXHIBIT D

SUMMARY

OF COST

ANALYSIS

FOR PROVIDING INCREMENTAL

EFFLUENT AMMONIA-NITROGEN REMOVAL AT THE

NOVEON-HENRY

PLANT

---

WWTF Component

Basis

PC

Tank

PVC Tank

Effluent

Effluent

Effluent

Effluent

Effluent

Struvite

Effluent

BP

Non-PC

Combined

Stripping

Stripping

Stripping

Stripping

Stripping

Stripping

Stripping

Precipitation

Chlorination

Nitrification

Nitrification

W/

Off.gas

w!o Off-gas

W/

Off-gas

No

Off-gas

No Off.gas

No

Off-gas

No Off-gas

75

removal

50

removal

25

removal

Additional Operations!

Maintenance Labor

‘LaborHours

800

800

1500

1300

1300

1000

1000

200

1500

1500

1500

*

Annual Cost,

$

$40/hr

32000

32000

60000

52000

52000

40000

40000

8000

60000

60000

60000

Electrical

Usage

‘hp

162

75

545

505

450

300

300

1

10

25

250

kwh

1058664

490122

3561553

3300155

2940732

1960488

1960488

6535

65350

163374

1633740

*AnnuaICost,$

$0.06/kwh

63520

29407

213693

198009

176444

117629

117629

392

3921

9802

98024

Maintenance Materials

*

LowEnd Equipment

Costs,

$

330,000

40,000

2106000

1263600

1013600

631800

379080

15000

375000

222,000

890,000

AnnuaiCosts,$

5ofECosts

16500

2000

105300

63180

50680

31590

18954

750

18750

11100

44500

Chemical

Costs

*

50

NaOH,

$ year

$240/ton

0

1770431.04

434000

434000

434000

217000

108500

0

955541

217772

742484

98

H2S04, S/year

$46/ton

0

24238

141000

119850

119850

70500

35250

0

0

0

45333

*

75

H3PO4, S/year

$335/ton

0

0

0

0

0

0

0

407160

0

0

0

*

62

Mg(OH)2, S/year

$220/ton

0

0

0

0

0

0

0

235205

0

0

0

*

98

HCI, $Iyear

$70/ton

0

0

0

0

0

0

0

0

0

0

0

*

Chlorine Gas, S/year

$50/ton

0

0

0

0

0

0

0

0

72681

0

0

Annual Costs

s/year

0

1794669

575000

553850

553850

287500

143750

642365

1028222

217772

787817

Annual

ResIn

Replacement, S/year

$90/cu ft

0

0

0

0

0

0

0

0

0

0

0

Annual

Off-site

Disposal, S/year

$0.10/gal

Natural Gas Cost, $/

year

Annual

Cost, S/year

$0.06/therm

18240

0

0

0

0

0

0

0

0

0

0

SubtotalAnnual

Costs,

S/year

130260

1858076

953993

867039

832974

476719

320333

651507

1110893

298674

990341

Contingency (10),$/yr

13026

185808

95399

86704

83297

47672

32033

65151

111089

29867

99034

Total Annual

Cost, 5/year

143286

2043884

1049393

953743

916271

524391

352367

716657

1221982

328542

1089375

Present Worth of Annual

Costs

$

10 years

961448

13714462

7041424

6399617

6148181

3518665

2364380

4808771

8199501

2204516

7309707

8 percent interest

Capital Costs, $

1,345,138

344,023

6,983,076

4,522,426

3,770.418

2,453,930

1.541.358

253,748

1,526,625

2.676,729

4,397,370

Total Present Worth, $

2,306,586

14,058,484

14,024.500

10,922,043

9,918,598

5,972,595

3,905,738

5,062,519

9,726,126

4,881,245

11,707,077

Average

NH3-N Removal, lbs/day

247

147

864

864

648

432

216

217

891

423

891

Average NH3-N Removal,

27.2

16.2

95.0

95.0

71.3

47.5

23.8

23.9

98.0

46.5

98.0

Present Worth Cost,

$Jlb NH3-N

2.56

26.13

4.45

3.47

4.20

3.79

4.96

6.39

2.99

3.16

3.60

---

Additional

Operations!

Maintenance Labor

*

Labor Hours

*

Annual

Cost,

$

$40/hr

Electrical Usage

*hp

25

18.75

12.5

6.25

225

168.75

112.5

56.25

kwh

163374

122531

81687

40844

22727273

1470366

1102775

735183

367592

*

Annual Cost, $

$0.06/kwh

9802

7352

4901

2451

1363636

88222

66166

44111

22055

Maintenance Materials

*

LowEnd Equipment

Costs,

$

*

Annual Costs,

$

5

ofE Costs

Chemical Costs

*

50

NaOH,

$

year

$240/ton

*

98

H2SO4, S/year

$46/ton

*

75

H3P04, S/year

$335/ton

*

62

Mg(OH)2, $/year

$220/ton

*

98

HCI,

S/year

$70/ton

• Chlorine Gas, S/year

$50/ton

Annual Costs, S/year

Annual ResIn Replacement, S/year

$90/cu ft

Annual Off-site Disposal. s/year

$0.10/gal

Natural Gas Cost, 5! year

Annual Cost, s/year

$0.06/therm

Subtotal Annual Costs, S/year

Contingency (10),5/yr

Total Annual Cost, S/year

Present Worth ofAnnual Costs

5

10 years

8 percent interest

Capital Costs,

5

Total Present Worth,

$

Average NH3-N Removal, lbs/day

Average NH3-N Removal,

Present Worth Cost, $/lb NH3.N

WWTF Component

Basis

Effluent

Effluent

Effluent

Effluent

Ozonation

Tertiary

Tertiary

Tertiary

Tertiary

Ion

Exchange

Ion

Exchange

Ion

Exchange

Ion Exchange

Nitrification

Nitrification

Nitrification

Nitrification

75

removal

50

removal

25

removal

75

removal

50

removal

25

removal

1500

1500

1500

1500

750

1500

1500

1500

1500

60000

60000

60000

60000

30000

60000

60000

60000

60000

284000

227200

170400

85200

2300000

444000

355200

266400

133200

14200

11360

8520

4260

115000

22200

17760

13320

6660

129861

97396

64930

32465

226145

458660

343995

229330

114665

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

17044

12783

8522

4261

0

0

0

0

0

0

0

0

0

0

0

0

0

0

146905

110179

73453

36726

226145

458660

343995

229330

114665

242449

181837

121224

60612

0

0

0

0

0

50727

38045

25363

12682

0

0

0

0

0

0

0

0

0

524083

408772

293462

176731

1734781

629082

487921

346761

203380

52408

40877

29346

17673

173478

62908

48792

34676

20338

576492

449650

322808

194404

1908259

691990

536713

381437

223718

3868259

3017150

2166041

1304450

12804419

4643251

3601346

2559441

1501151

1,198,024

1.095.472

787,814

480,157

7,523,300

6,762,000

6,223,800

4,264,200

2,304,600

5,066,283

4,112,621

2,953,855

1,784,607 20,327,719

11,405,251

9,825,146

6,823,641

3,805,751

891

668

445

223

891

891

668

445

223

98.0

73.5

49.0

24.5

98.0

98.0

73.5

49.0

24.5

1.56

1.69

1.82

2.20

6.25

3.51

4.03

4.20

4.68

---

m

:3-

m

---

EXHIBIT E

SUMMARY

TABLE

COMPARING

COST, EFFLUENT AMMONIA-NITROGEN

REDUCTION PERCENTAGES, RELIABILITY,

AND

PROS

AND

CONS OF

ALTERNATIVE EFFLUENT AMMONIA-NITROGEN REDUCTION

PROCESSES FOR THE NOVEON-HENRY

PLANT

---

-

--

-I

Comparison of Costs and Removals of Effluent NH3-N Removal Processes

for theNoveon-Henry Wastewater Treatment Facility with 10-Year Project

Life

Annual

Operating

Process

Capital Cost

($

millions)

Cost

($

millions/year)

Present Worth Cost’

Effluent NH3-N Removal

(Average )

($

millions)

($/lb NH3-N removed)

PC Tank Strippingwith

1.35

0.130

2.21

2.45

27

Off-gas Control

1.31

0.125

2.15

4.60

14

PVC Tank Stripping

0.344

2.04

14.1

26.13

16

without

Off-gas Control

0.317

2.03

14.0

51.89

8

Effluent

Strippingwith

6.98

1.05

14.1

4.42

95

Off-gas Control

Effluent

Strippingwithout

4.52

0.894

10.5

3.34

95

Off-gas Control

3.77

0.850

9.5

3.83

75

2.45

0.483

5.7

3.44

50

1.54

0.332

3.8

4.59

25

Struvite

Precipitation

0.254

0.669

4.74

5.99

24

0.254

0.539

3.87

6.53

18

Effluent Breakpoint

1.53

1.22

9.73

2.99

98

Chlorination

P~\PROJ\23417

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Page 1

of 2

---

Comparison of Costs and Removals of EffluentNH3-N Removal Processes

for the Noveon-Henry Wastewater Treatment Facility with 10-Year Project

Life

Process

Capital Cost

($

millions)

Annual

Operating

Cost

($

millions/year)

Present Worth Cost

-

Effluent NH3-N Removal

(Average )

($

millions)

($/lb NH3-N removed)

Non-PC Nitrification

2.68

0.329

4.88

3.16

47

Combined Single-Stage

4.40

1.09

11.7

3.60

98

Nitrification

•

MBT Removal Process

0.86

0.441

3.82

Less Than 25

•

WWTF

Upgrades

3.54

0.649

7.88

0

EffluentIonExchange

1.20

1.10

0.79

0.48

0.688

0.533

0.379

0.222

5.82

4.67

3.33

1.97

1.79

1.88

2.01

2.38

98

75

50

25

Effluent Ozonation

7.52

1.91

20.3

6.25

98

TertiaryNitriflcation

6.76

6.22

4.26

2.30

0.692

0.536

0.381

0.223

11.4

9.83

6.82

3.81

3.51

4.03

4.20

4.68

98

75

50

25

ai

0 years at 8

interest.

P:\PROJ\23417

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Page 2 of 2

---

Comparison of Costs and Removals of Effluent NH3-N Removal Processes

for the Noveon-Henry Wastewater Treatment Facility

with

20-Year Project

Life

Annual Operating

Process

Capital Cost

($

millions)

Cost

($

millions/year)

Present Worth

Costa

EffluentNH3-N Removal

(Average )

($

millions)

($/lb NH3-N removed)

PC Tank Strippingwith

1.35

0.130

2.63

1.46

27

Off-gas Control

1.31

0.125

2.54

2.72

14

PVC Tank Stripping

-

0.344

2.04

20.4

18.90

16

without Off-gas Control

0.317

2.03

20.2

37.43

8

Effluent Stripping with

6.98

1.05

17.3

2.71

95

Off-gas Control

Effluent Stripping without

4.52

0.894

13.3

2.12

95

Off-gas Control

-

3.77

0.850

12.1

2.44

75

2.45

0.483

7.2

2.17

50

1.54

0.332

4.8

2.90

25

Struvite

Precipitation

0.254

0.669

6.8

4.30

24

0.254

0.539

5.5

-

4.64

18

Effluent Breakpoint

1.53

1.22

13.5

1.08

98

Chlorination

-

P:\PROJ\23417

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Page 1 of2

---

Comparison of Costs and Removals of Effluent NH3-N Removal Processes

for the Noveon-Henry Wastewater Treatment Facility with 20-Year Project

Life

Process

Capital

Cost

($

millions)

Annual

Operating

Cost

($

millions/year)

Present Worth Cost

Effluent NH3-N Removal

(Average

)

($

millions)

($/lbNH3-N removed)

Non-PC Nitrification

2.68

0.329

5.9

1.91

47

Combined Single-Stage

4.40

1.09

15.1

2.32

98

Nitrification

•

MBT

Removal Process

0.86

0.441

5.2

Less Than 25

•

WWTF

Upgrades

3.54

0.649

9.9

-

-

0

Effluent

IonExchange

1.20

1.10

0.79

0.48

0.688

0.533

0.379

0.222

8.0

6.3

4.5

2.7

1.23

1.27

1.36

1.63

98

75

50

25

EffluentOzonation

7.52

1.91

26.3

4.05

98

Tertiary Nitrification

.

6.76

6.22

4.26

2.30

0.692

0.536

0.381

0.223

13.6

11.5

8.0

4.5

2.09

2.36

2.46

2.76

98

75

50

25

years at 8

interest.

P:\PROJ\23417

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Page 2

of 2

---

Comparison of Removals

and

Reliability of Effluent NH3-N Removal Processes

for theNoveon-Henry Wastewater Treatment Facility

Process

Effluent NH3-N Removal

Reliability

(Average

)

Rating1

Comments

PC Tank Strippingwith

27

8

Involves adding surface aerator, oversized withdrawal fan, off-gas collection

Off-gas Control

and thermal oxidation of off-gas. Off-gas collection and treatment are

needed

for VOC control. No chemical addition required since PC Tank

contents are

normally pH

11

s.u. Simple to operate. Performance will vary as volatile amine

content varies in wastewater. Average removals of 0 to 27 percent could be

achieved

by

varying

the

size ofthe surface aerator placed in the

tank.

PVCTank Stripping

16

7

Involves adding caustic addition

and

surface aerator toPVCtank contents.

without Off-gas Control

Acid additionin

primary

system will be required to lowerpH to 9.0 s.u. Simple

to operate. Strong foaming potential in PVCTank which would reduce

effectiveness. Performance will vary

based on production discharges ofNH3-N

and volatile amines, and NH3-N returned in sludge dewatering

filtrate and

tertiary filter backwash. Removals of 0 to

16 percent could be achieved by

varying the size of the surface aerator placed in the tank.

Wifi increase effluent

TDS.

Effluent

Stripping

with

95

7

Involves pumping sand filter effluent through two

packed

towers in series.

Off-gas Control

Caustic is added to increasepH to 11.5 s.u. and acid is added to lower the

treated effluentpH to 8 s.u. Off-gas is directed to an acid scrubber for recovery

of (NH4)2SO4. Scrubber discharge would be disposed

off-site. Complex to

operate. Equipmentmustbe housed in heated building to prevent freezing.

Fouling of tower mediawith precipitants is anticipated. Removals of

75

to

95

percent would be achieved

by treating the whole effluent through different

sized columns. Removals of 25 to 50 percent would be achieved by treating

only a portion

of the final

effluent.

Will

increase effluentTDS.

Page 1 of4

---

Comparison of Removals

and Reliability

of Effluent NH3-N Removal Processes

for the Noveon-Henry Wastewater Treatment Facility (Continued)

Process

Effluent NH3-N Removal

Reliability

(Average

)

Rating1

Comments

Effluent Stripping without

95

8

Same as above but without off-gas

collection and treatment.NH3-N would be

Off-gas

Control

discharged to atmosphere.

Will

increase effluentTDS.

Struvite Precipitation

24

6

Involves feedingmagnesium hydroxideand

phosphoric acid to

existingprimary

treatment system. Simple to operate. However,the precipitantis prone to foul

pumps

and

piping. Removal could be varied between 18

and

24 percent

dependingupon the quantity ofmagnesium hydroxide added. Performance will

vary strictlyas a functionofinfluentNH3-N load.

Will

increase effluentTDS.

Effluent Breakpoint

98

9

Involves routing secondary clarifier effluent through chlorinationstep prior to

Chlorination

tertiary

filtration. Causticis fed to maintainpH control. Reliable process.

Creates safety concernsandmayform chlorinated organics.

Will

increase

effluentTDS.

Non-PC Nitrification

47

-

7

Involves using existing activated sludge system to provideBOD removal

and

nitrification ofPVCwastewater. Treated effluent from

this

systemwould be

combined

with PC

wastewaterand treated

in

new activated sludge system.

Complex system to operate. Two WWTFs that would be subject to upset.

Performance would vary as a function of PVC NH3-N and

amine loading.

Will

increase

effluent

TDS.

Page 2 of 4

P:\PROJ\23417

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Alternative NH3.doc